- Petitioner
- Ford Philippines
- Respondent
- Court of Appeals
- Citation
- G.R. No. 99039
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Francisco, J.
- Decided
- February 3, 1997
Summary
Manuel I. Oboza, Ford Philippines' General Sales Manager from 1980-1983, was dismissed due to redundancy in January 1983. He filed a civil damages case alleging bad faith dismissal under Civil Code Articles 19 and 21, claiming Ford used redundancy as subterfuge to secure extension of foreign employee Malcolm Johnston's work permit. The trial court dismissed the case, but the Court of Appeals reversed, finding bad faith based on timing between Ford's DOLE memorandum criticizing Oboza and the redundancy notice. The Supreme Court reversed the CA, finding no bad faith because: the DOLE memorandum was filed while Oboza was still employed, the permit extension was denied anyway, other understudies were available, and Ford was in genuine financial distress. The Court emphasized that bad faith must be proven by clear and convincing evidence, and moral damages in employment cases require showing the dismissal was attended by bad faith, fraud, or oppressive conduct.