Short answer. Possibly. There is no general right not to be embarrassed at work, but Article 19 requires every person to act with justice and good faith in exercising his rights. A supervisor entitled to correct your work is not entitled to do it in a manner aimed at degrading you.
What the law says
Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.
Civil Code, Article 19 — Abuse of Rights (Principle of Human Relations). Read the full provision →
What the law says
Every person shall respect the dignity, personality, privacy and peace of mind of his neighbors and other persons.
Civil Code, Article 26 — Respect for Dignity, Privacy and Peace of Mind. Read the full provision →
The right to discipline is not a licence
Your employer has a real right to correct work and impose discipline, and the answer does not turn on denying it. It turns on Article 19: Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith. The provision does not ask whether the right existed. It asks how it was used. A correction delivered privately and a correction staged in front of an audience serve the same disciplinary purpose only if the audience adds something legitimate, and usually it does not.
Where dignity becomes a cause of action
Article 26 is more specific: Every person shall respect the dignity, personality, privacy and peace of mind of his neighbors and other persons. It then says the acts it lists produce a cause of action for damages, prevention and other relief even though they may not constitute a criminal offense, and the fourth of them is vexing or humiliating another on account of his religious beliefs, lowly station in life, place of birth, physical defect, or other personal condition. That last phrase is the one that matters at work. An outburst about a spreadsheet is not it; an outburst that attacks who you are may well be.
What separates a bad day from a claim
Courts look for something beyond unpleasantness: a pattern rather than one lost temper, words directed at the person rather than the error, an audience assembled for the purpose, and a purpose that was to injure rather than to manage. Article 20 supplies the remedy where conduct also breaks a legal rule, obliging anyone who wilfully or negligently causes damage contrary to law to indemnify the person harmed. Article 2219 lists the acts referred to in Article 26 among the cases where moral damages may be recovered, and Article 2217 describes what those cover, including wounded feelings and social humiliation.
What to do this week
Write down what was said, as close to verbatim as you can manage, with the date, the place and the names of everyone present, and do it now rather than from memory in six months. Keep any message, memo or chat thread around the incident, and note whether it was the first time. If the treatment is also affecting your employment status, that is a separate track with its own procedures and its own timelines, and the two should be assessed together rather than one at a time.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Hongkong and Shanghai Banking Corporation Limited vs. Cecilia Diez Catalan, G.R. No. 159590, October 18, 2004 — read the decision on LawPhil →
- Equatorial Realty, et al. vs. Mayfair Theater, G.R. No. 106063, November 21, 1996 — read the decision on LawPhil →
- Metroheights Subdivision Homeowners Association, Inc. vs. CMS Construction and Development Corporation, et al, G.R. No. 209359, October 17, 2018 — read the decision on LawPhil →
- Adelaida C. Navarro-Banaria vs. Ernesto A. Banaria, et al, G.R. No. 217806, July 28, 2020 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 19 — Abuse of Rights (Principle of Human Relations)
- Civil Code, Article 20 — Damage Contrary to Law
- Civil Code, Article 26 — Respect for Dignity, Privacy and Peace of Mind
- Civil Code, Article 2217 — Moral Damages Defined