Elizabeth L. Diaz v. Georgina R. Encanto

Summary

Professor Elizabeth Diaz sued UP officials for damages after her 1988 sabbatical leave application was denied and salaries withheld. The RTC initially awarded damages finding unreasonable delay, but the Court of Appeals reversed, finding no bad faith. The Supreme Court affirmed, ruling that sabbatical leave is a privilege, not a right, and the denial was justified by teaching staff shortage. The Court found no abuse of rights under Civil Code Articles 19-20. Diaz was awarded only unpaid salaries for periods when she actually rendered service - when her name was removed from schedules without her knowledge and when she taught but was required to submit administrative forms. The case establishes that university officials' discretionary decisions on sabbatical leaves, when made in good faith based on legitimate institutional needs, do not constitute actionable wrongs even if they cause employee disappointment or financial impact.