### Facts:
Valentin Abad, a civil service eligible who passed the Patrolmen’s Examination, was appointed as a security guard at the Civil Aeronautics Administration (CAA) in Mactan on July 1, 1968, initially for a month. His service was extended several times until his termination on January 1, 1972. CAA argued that Abad was not dismissed but his temporary appointment lapsed. The case progressed from the Court of First Instance of Cebu, which ruled in favor of Abad, ordering his reinstatement and awarding damages. The decision was affirmed by the Intermediate Appellate Court. Upon reaching the Supreme Court, the appeal’s focal point narrowed down to the award of damages since Abad’s reinstatement became moot upon his death.
### Issues:
1. Whether the termination of Valentin Abad’s service was conducted in a lawful and just manner.
2. Whether the award of damages to Abad (now his heirs) was warranted based on the circumstances surrounding his termination.
### Court’s Decision:
The Supreme Court affirmed the decisions of both the trial and the appellate courts, finding no reversible error. It was determined that Abad’s termination was both “malicious and arbitrary,” noting the discrepancy in the treatment between employees with and without civil service eligibilities. Particularly, the continuity of employment for less-qualified, non-eligible employees over Abad, who possessed the appropriate eligibility, was criticized. The decisions from lower courts ordering reinstatement and the award of damages (moral and actual) along with attorney’s fees were upheld.
### Doctrine:
The core doctrine reasserted in this case revolves around the security of tenure under the Civil Service Law. Specifically, the case underscores that non-eligibles who have served for more than five years, even under temporary appointments, acquire a right to continue in their position under certain conditions, emphasizing protection against arbitrary dismissals.
### Class Notes:
– **Security of Tenure in Civil Service**: An employee, even under a temporary appointment, is protected against arbitrary dismissal as long as they meet specified conditions such as serving for more than five years and being subject to certain procedures.
– **Civil Service Eligibility**: Holds significant weight in employment within the government and government-controlled corporations, offering a layer of job security against arbitrary termination.
– **Award of Damages in Employment Disputes**: Demonstrates circumstances under which courts may grant moral and actual damages, including attorney’s fees, in cases of unjust and arbitrary termination.
### Historical Background:
The case reflects the Philippines’ strict legal frameworks around employment in the public sector, especially concerning civil service eligibilities and security of tenure. It touches upon the broader theme of fairness and justice within governmental employment practices, emphasizing the importance of adherence to established civil service rules and regulations to protect employees from arbitrary and unjust actions.
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