ASG Law

Category: Torts

  • Vicarious Liability: Employer’s Duty in Employee Negligence

    In Jessica P. Maitim A.K.A. “Jean Garcia” vs. Maria Theresa P. Aguila, the Supreme Court affirmed the principle of vicarious liability, holding an employer solidarily liable for the negligent acts of their employee. This decision underscores the responsibility of employers to exercise due diligence in both the selection and supervision of their employees. The ruling emphasizes that employers cannot simply claim they have hiring procedures and supervisory policies; they must provide concrete proof of compliance. This case serves as a critical reminder for employers to prioritize employee safety and exercise comprehensive oversight to prevent potential harm to others.

    The Driveway Accident: Who Bears Responsibility?

    This case revolves around an unfortunate accident that occurred in the Grand Pacific Manor Townhouse, where Jessica Maitim and Maria Theresa Aguila resided. On April 25, 2006, Angela, the six-year-old daughter of Maria Theresa, was sideswiped by Jessica’s vehicle while it was being driven by Restituto Santos, Jessica’s driver. The incident resulted in Angela sustaining a fractured right leg and other injuries. The central legal question is whether Jessica Maitim, as the employer, should be held vicariously liable for the negligence of her driver, Restituto Santos.

    The doctrine of res ipsa loquitur played a crucial role in the court’s decision. This doctrine, as explained in Solidum vs. People, means “the thing or the transaction speaks for itself.” It applies when the injury-causing object is under the defendant’s management, and the accident typically wouldn’t occur if proper care was exercised. In such cases, negligence is inferred unless the defendant provides an adequate explanation. The Supreme Court has reiterated the applicability of res ipsa loquitur in vehicular accidents as seen in UPCB General Insurance Co. v. Pascual Liner, Inc.

    In this case, the fact that Angela was hit by Jessica’s vehicle, driven by Restituto, was undisputed. Additionally, Angela’s injuries from the collision were also not in question. These established facts triggered the application of res ipsa loquitur, leading to the inference of negligence on Restituto’s part. Consequently, Restituto bore the burden of proving that he was not negligent at the time of the incident. This presumption of negligence highlights the high standard of care expected from drivers, especially in shared residential areas.

    The court found that Restituto failed to overcome this presumption. Even though driving slowly in a narrow driveway is generally expected, the severity of Angela’s injuries suggested otherwise. The court reasoned that a reasonably prudent driver would have foreseen the possibility of residents, including children, exiting their houses. Therefore, utmost caution was required, regardless of any signals from a guard. The fact that Angela was dragged for three meters with a completely fractured leg indicated a lack of due care on Restituto’s part.

    Furthermore, Jessica Maitim’s defense lacked sufficient evidence to rebut the presumption of her driver’s negligence. She merely alleged that Restituto was driving with due care and was not speeding, without providing any corroborating evidence. Allegations alone hold no probative value, and the court emphasized that factual claims must be supported by concrete proof. This failure to present evidence reinforced the conclusion that Restituto was indeed negligent, thus setting the stage for the determination of vicarious liability.

    Article 2176 of the Civil Code establishes the foundation for quasi-delict, stating:

    Article 2176. Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter.

    Building on this, Article 2180 of the Civil Code provides the basis for the concept of vicarious liability:

    Article 2180. The obligation imposed by article 2176 is demandable not only for one’s own acts or omissions, but also for those of persons for whom one is responsible.

    Employers shall be liable for the damages caused by their employees and household helpers acting within the scope of their assigned tasks, even though the former are not engaged in any business or industry.

    The responsibility treated of in this article shall cease when the persons herein mentioned prove that they observed all the diligence of a good father of a family to prevent damage.

    Applying these provisions, the court emphasized that when an employee’s negligence causes injury, a presumption arises that the employer was negligent in either selecting or supervising the employee. This liability is direct and immediate, not contingent on prior action against the employee or a showing of the employee’s insolvency. Therefore, Jessica Maitim had to prove that she exercised the diligence of a good father of a family in selecting and supervising Restituto to avoid vicarious liability.

    Jessica argued that Restituto had a clean 12-year driving record and submitted police and NBI clearances prior to his employment. However, she failed to provide any evidence to support these claims. The court reiterated that bare allegations are insufficient to overcome the presumption of negligence. As highlighted in Filipinas Synthetic Fiber Corporation v. De Los Santos, employers must submit concrete proof, including documentary evidence, to demonstrate compliance with their duty of diligence in selecting and supervising employees.

    Specifically, the Court in Filipinas Synthetic Fiber Corporation v. De Los Santos stated:

    To fend off vicarious liability, employers must submit concrete proof, including documentary evidence, that they complied with everything that was incumbent on them.

    Maitim’s failure to provide such evidence led the court to conclude that she did not meet the required standard of diligence. Thus, the presumption of negligence against her stood, making her solidarily liable with Restituto for the damages caused. This reinforces the principle that employers must actively ensure their employees are competent and well-supervised to prevent harm to others. It’s not enough to simply have policies; those policies must be implemented and monitored consistently.

    The argument of contributory negligence on Maria Theresa Aguila’s part was also dismissed. Jessica alleged that Maria Theresa failed to properly supervise her daughter, allowing her to exit the house towards the driveway. However, the court noted that the driveway was a common area and part of the Aguila’s residence. Angela was on her way to board their car, and there was a reasonable expectation of safety within their residential premises. Moreover, the narrow driveway should have prompted anyone driving through it to proceed with utmost caution. Given these circumstances, Maria Theresa was not negligent in allowing her daughter to walk towards their garage.

    In summary, the Supreme Court found no reason to deviate from the lower courts’ findings. Jessica Maitim and Restituto Santos failed to rebut the presumption of negligence lodged against them. There was no contributory negligence on the part of Maria Theresa Aguila. Consequently, Jessica was held solidarily liable with Restituto for Angela’s injuries. This case reaffirms the significance of vicarious liability and the employer’s critical role in ensuring the safety and well-being of others through diligent employee selection and supervision.

    FAQs

    What is vicarious liability? Vicarious liability holds one person or entity responsible for the negligent actions of another, even if the first party was not directly involved in the act. In this case, the employer is held liable for the actions of the employee.
    What is the doctrine of res ipsa loquitur? Res ipsa loquitur means “the thing speaks for itself.” It allows an inference of negligence when the circumstances suggest that the injury would not have occurred without negligence, and the instrumentality causing the injury was under the defendant’s control.
    What must an employer prove to avoid vicarious liability? An employer must prove that they exercised the diligence of a good father of a family in both the selection and supervision of their employee. This requires presenting concrete evidence, not just allegations, of their hiring and supervision practices.
    What kind of evidence is needed to prove due diligence? Evidence may include documented hiring procedures, employee training records, performance evaluations, safety protocols, and records of disciplinary actions. The key is to demonstrate active and consistent effort in ensuring employee competence and safety.
    What is contributory negligence? Contributory negligence occurs when the injured party’s own negligence contributes to the cause of their injuries. If proven, it can reduce the amount of damages the injured party can recover.
    Why was contributory negligence not applicable in this case? The court determined that the mother was not negligent in allowing her child to be in the driveway because it was within their residential premises and a shared area. She could reasonably expect that drivers would exercise caution.
    What is the significance of a clean driving record in vicarious liability cases? While a clean driving record may be a factor, it is not sufficient to automatically absolve an employer of vicarious liability. The employer must still prove due diligence in both the selection and supervision of the employee, regardless of their past record.
    What are the practical implications of this ruling for employers? Employers must prioritize implementing robust hiring and supervision practices. They must keep detailed records of these practices and ensure consistent compliance with safety protocols. This will help protect them from potential vicarious liability claims.

    The case of Jessica P. Maitim A.K.A. “Jean Garcia” vs. Maria Theresa P. Aguila serves as a stern reminder to employers about their responsibilities regarding employee conduct. The ruling highlights the importance of not only having policies and procedures in place, but also of diligently implementing and monitoring them to ensure employee competence and safety. This case underscores that employers must be proactive and accountable in their roles, or risk bearing the consequences of their employees’ negligence.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Jessica P. Maitim A.K.A. “Jean Garcia” vs. Maria Theresa P. Aguila, G.R. No. 218344, March 21, 2022

  • Time Limits in Medical Negligence Claims: Understanding Prescription in Philippine Law

    The Supreme Court ruled that a medical malpractice case, alleging negligence during surgery, was filed beyond the prescriptive period. The Court clarified that such cases are generally treated as quasi-delicts, subject to a four-year statute of limitations. This decision emphasizes the importance of filing medical negligence claims promptly to ensure legal recourse for alleged harm.

    Doctor’s Negligence or Breach of Contract? Unpacking a Medical Malpractice Suit

    This case revolves around Paolo Anthony C. De Jesus’s complaint against Dr. Romeo F. Uyloan, Dr. John Francois Ojeda, and Asian Hospital and Medical Center (AHMC) for damages allegedly arising from a botched gallbladder surgery. The central legal question is whether De Jesus’s claim is based on a breach of contract or a quasi-delict, as the applicable prescriptive period differs significantly between the two. This distinction is critical in determining whether De Jesus filed his lawsuit within the allowable time frame.

    De Jesus underwent a surgery performed by Dr. Uyloan and Dr. Ojeda at AHMC, initially planned as a laparoscopic cholecystectomy. However, the procedure was converted to an open cholecystectomy without his consent, leading to complications such as blood loss and bile duct injury. De Jesus argued that this constituted a breach of a “medical contract” and a failure to meet the expected standard of care. The doctors and the hospital countered that the claim was one of medical negligence, a quasi-delict, which had already prescribed because it was filed more than four years after the surgery.

    The Regional Trial Court (RTC) initially denied the motions to dismiss, finding that the issue of prescription was evidentiary and required further examination. However, the Court of Appeals (CA) reversed the RTC’s decision, holding that the case was indeed based on medical negligence and was time-barred. The Supreme Court then took up the case to determine whether the CA erred in its ruling.

    The Supreme Court began its analysis by clarifying the nature of its jurisdiction in Rule 45 petitions, emphasizing that it primarily reviews questions of law, not fact. The Court acknowledged that prescription could be a question of fact or law, depending on whether the dispute revolves around the truth of factual allegations or the interpretation of legal principles. In this instance, the Court determined that the core issue—whether the claim had prescribed—was a question of law because it required interpreting the relevant provisions of the Civil Code regarding prescription periods.

    To resolve this legal question, the Court scrutinized De Jesus’s complaint to ascertain the true nature of his cause of action. The Court emphasized that medical malpractice claims typically arise from a violation of Article 2176 of the Civil Code, which governs quasi-delicts. Quasi-delict refers to acts or omissions causing damage to another, where there is fault or negligence but no pre-existing contractual relation. The crucial element here is the absence of a contractual tie.

    The Court defined medical malpractice as a specific form of negligence, characterized by a physician’s failure to exercise the degree of care and skill ordinarily employed by the medical profession under similar circumstances. This involves four essential elements: duty, breach, injury, and proximate causation. The physician must have a duty of care to the patient, which must be breached, leading to an injury that is proximately caused by the breach.

    In dissecting De Jesus’s complaint, the Supreme Court noted that while it mentioned a “medical contract,” the substance of the allegations focused on the doctors’ failure to meet the expected standard of care. The complaint detailed how the doctors allegedly deviated from accepted medical practices during the surgery, leading to the bile duct injury and subsequent complications. The Court cited Lucas v. Tuaño to underscore that a physician’s duty includes exercising the care, skill, and diligence that other reasonably competent physicians would use in similar cases.

    The Court emphasized that the mere invocation of a “medical contract” does not automatically transform a medical negligence claim into a contractual dispute. To establish a cause of action based on contract, the plaintiff must allege an express promise by the physician to provide specific medical treatment or achieve a particular result. Absent such an express agreement, the claim remains rooted in tort law, specifically medical negligence. The legal principle is that without a defined special contract where a doctor makes a promise about results, the claim defaults to being one about negligence.

    Absent an express contract, a physician does not impliedly warrant the success of his or her treatment but only that he or she will adhere to the applicable standard of care. Thus, there is no cause of action for breach of implied contract or implied warranty arising from an alleged failure to provide adequate medical treatment. This allegation clearly sounds in tort, not in contract; therefore, the plaintiff’s remedy is an action for malpractice, not breach of contract. A breach of contract complaint fails to state a cause of action if there is no allegation of any express promise to cure or to achieve a specific result. A physician’s statements of opinion regarding the likely result of a medical procedure are insufficient to impose contractual liability, even if they ultimately prove incorrect.

    In this case, De Jesus failed to demonstrate any express promise from Dr. Uyloan or Dr. Ojeda guaranteeing a specific outcome. Therefore, the Court concluded that his claim was indeed one for medical negligence, subject to the four-year prescriptive period for quasi-delicts under Article 1146 of the Civil Code. As the lawsuit was filed more than five years after the surgery, the Court held that it was time-barred.

    This decision underscores the critical importance of understanding the nature of legal claims and the applicable time limits for filing lawsuits. In medical malpractice cases, the distinction between a contract-based claim and a quasi-delict is pivotal. Unless there is an express agreement guaranteeing specific medical results, medical negligence claims will generally be treated as quasi-delicts, subject to a shorter prescriptive period.

    FAQs

    What was the key issue in this case? The key issue was whether the medical malpractice claim was based on breach of contract or quasi-delict, as this determined the applicable prescriptive period. The Supreme Court determined it was a quasi-delict.
    What is the prescriptive period for quasi-delicts in the Philippines? The prescriptive period for quasi-delicts, including medical negligence, is four years from the date the cause of action accrues, as stated in Article 1146 of the Civil Code. This means a lawsuit must be filed within four years of the negligent act or omission.
    What is required to establish a medical malpractice claim based on contract? To establish a medical malpractice claim based on contract, there must be evidence of an express promise by the physician to provide specific medical treatment or achieve a particular result. A general expectation of care is not sufficient.
    When did the cause of action accrue in this case? The cause of action accrued on September 15, 2010, the date when Dr. Uyloan and Dr. Ojeda performed the allegedly negligent operation on De Jesus’s gallbladder. This marked the start of the four-year prescriptive period.
    Why was the claim dismissed in this case? The claim was dismissed because it was filed on November 10, 2015, more than five years after the surgery, exceeding the four-year prescriptive period for quasi-delicts. Thus, the claim was considered time-barred.
    What is the significance of a physician-patient relationship? A physician-patient relationship establishes a legal duty of care, requiring the doctor to provide a standard of care that a reasonably competent doctor would use in similar circumstances. A breach of this duty can lead to a medical negligence claim.
    How does the Civil Code define quasi-delict? Article 2176 of the Civil Code defines quasi-delict as an act or omission that causes damage to another, where there is fault or negligence but no pre-existing contractual relation between the parties. This forms the basis for many medical negligence claims.
    What are the four elements of medical negligence? The four elements of medical negligence are: (1) a duty of care owed by the physician to the patient; (2) a breach of that duty; (3) an injury suffered by the patient; and (4) proximate causation, meaning the breach of duty directly caused the injury.
    Can a hospital be held liable for the negligence of its doctors? Yes, a hospital can be held liable for the negligence of its doctors under certain circumstances, particularly if the hospital failed to properly supervise or accredit its medical staff. This is based on the doctrine of corporate responsibility.

    This Supreme Court decision serves as a reminder for patients to be vigilant about their rights and to seek legal advice promptly if they believe they have been victims of medical negligence. Understanding the applicable prescriptive periods is crucial to ensuring that legal remedies remain available.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: PAOLO ANTHONY C. DE JESUS VS. DR. ROMEO F. UYLOAN, G.R. No. 234851, February 15, 2022

  • Reckless Imprudence: Penalties for Damage to Property and Physical Injuries

    The Supreme Court has clarified the penalties for reckless imprudence resulting in both damage to property and physical injuries. The Court emphasized that reckless imprudence is a distinct crime, not merely a way of committing one, and thus, the penalties for each consequence—physical injuries and property damage—should be imposed separately. This means that in addition to facing penalties for the physical injuries caused, an individual will also be fined for the damage to property. The Court abandoned its previous stance of ‘complexing’ the offense, ensuring that penalties align with the severity of each consequence stemming from the reckless act.

    When a Careless Overtake Leads to Multiple Injuries and Property Damage

    In 2013, Francis O. Morales, while driving a Mitsubishi Delica Van, recklessly overtook a vehicle, colliding with an Isuzu Jitney. This resulted in serious physical injuries to the Jitney’s driver, Rico Mendoza, slight physical injuries to passengers Lailani Mendoza and Myrna Cunanan, and significant damage to the Jitney. Morales was charged with reckless imprudence resulting in damage to property and multiple physical injuries. The case reached the Supreme Court, prompting a review of how such quasi-offenses should be penalized, particularly regarding the imposition of fines for property damage alongside penalties for physical injuries. The central legal question was whether the fine for property damage should be applied when the same act of recklessness also causes physical harm.

    The Municipal Trial Court in Cities (MTCC) initially found Morales guilty, a decision affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA). The CA modified the penalties and damages awarded, but the core conviction stood. Morales then appealed to the Supreme Court, arguing that he wasn’t negligent and that the damages awarded were baseless. The Supreme Court’s decision hinged on the correct interpretation of Article 365 of the Revised Penal Code (RPC), specifically regarding how to penalize acts of reckless imprudence that lead to multiple consequences.

    At the heart of the matter was Article 365 of the RPC, which addresses imprudence and negligence. This article defines reckless imprudence as performing or failing to perform an act voluntarily, without malice, but with inexcusable lack of precaution, resulting in material damage. The Supreme Court, in this case, reaffirmed the doctrine established in Ivler v. Hon. Judge Modesto-San Pedro, which distinguishes reckless imprudence as a distinct crime, not merely a manner of committing one. This distinction is crucial because it dictates how related penalties are applied.

    To fully understand the ruling, it’s essential to delve into the legal precedents that shaped the Court’s decision. The Supreme Court carefully considered its past rulings, particularly the conflicting interpretations in People v. De los Santos and Angeles v. Jose. De los Santos had previously suggested that Article 48 of the RPC, which deals with complex crimes, could apply to quasi-offenses. This meant that a single act resulting in multiple felonies could be treated as one crime, with the penalty for the most serious crime applied.

    However, the Supreme Court abandoned this approach, emphasizing that applying Article 48 to quasi-offenses blurs the lines between intentional crimes and those resulting from negligence. As the Court explained, in intentional crimes, the focus is on the act itself, while in negligence, it’s the mental attitude or condition behind the act—the dangerous recklessness—that’s penalized. To illustrate this point, consider the following quote from Quizon v. The Justice of the Peace of Pampanga:

    In international crimes, the act itself is punished; in negligence or imprudence, what is principally penalized is the mental attitude or condition behind the act, the dangerous recklessness, lack of care or foresight, the imprudencia punible.

    The Court explicitly rejected the application of Article 48 to quasi-offenses, reinforcing the principle that reckless imprudence is a crime in itself. This means that each consequence of the imprudent act—whether physical injury or property damage—must be penalized separately. This approach aligns with the intent of Article 365, which aims to address the specific harm caused by the negligent act.

    Building on this principle, the Court addressed the specific issue of whether the fine for damage to property, as outlined in the third paragraph of Article 365, should be imposed when the reckless act also results in physical injuries. The relevant provision states:

    When the execution of the act covered by this article shall have only resulted in damage to the property of another, the offender shall be punished by a fine ranging from an amount equal to the value of said damages to three (3) times such value, but which shall in no case be less than Five thousand pesos (P5,000).

    The Court clarified that this provision applies even when physical injuries also result from the same act. In such cases, a fine for the property damage is imposed in addition to the penalties for the physical injuries. This interpretation ensures that all consequences of the reckless act are appropriately addressed.

    The Court underscored that prosecutors must ensure that all consequences of the negligent act are accounted for in a single Information, preventing the splitting of charges and upholding the accused’s right against double jeopardy. This means that an individual cannot be tried separately for each consequence of a single act of reckless imprudence. This is to prevent a strategy used in Ivler from being used again.

    In Morales’s case, the Court found that he was indeed guilty of reckless imprudence, as his act of overtaking without ensuring the road was clear directly led to the collision and resulting injuries and damage. The Court referenced Section 41 of R.A. No. 4136, the “Land Transportation and Traffic Code,” which mandates that drivers must ensure the left side of the highway is clearly visible and free of oncoming traffic before overtaking. Since Morales violated this regulation, he was presumed negligent under Article 2185 of the New Civil Code. The Court further ruled the last clear chance doctrine inapplicable, since Morales’s negligence was the direct cause of the incident.

    The Supreme Court modified the CA’s decision, sentencing Morales to public censure for each of the slight physical injuries inflicted on Rico Mendoza, Lailani Mendoza, and Myrna Cunanan. Additionally, he was ordered to pay a fine of P150,000.00 for the damage to property. Temperate damages were also awarded to the injured parties and the owner of the damaged jeepney. All monetary awards were subject to a six percent (6%) interest rate per annum from the finality of the Resolution until fully paid.

    FAQs

    What was the key issue in this case? The key issue was how to properly penalize reckless imprudence resulting in both damage to property and physical injuries, specifically whether to impose a fine for the property damage in addition to penalties for the physical injuries.
    What did the Supreme Court rule? The Supreme Court ruled that reckless imprudence is a distinct crime, and the penalties for each consequence, including fines for property damage and penalties for physical injuries, should be imposed separately.
    What is the significance of the Ivler doctrine? The Ivler doctrine, reaffirmed in this case, establishes that reckless imprudence is not merely a way of committing a crime but a distinct offense, preventing the ‘complexing’ of quasi-crimes and ensuring appropriate penalties for each consequence.
    What is the prosecutor’s role in these cases? Prosecutors must ensure that all consequences of a reckless or imprudent act are accounted for in a single Information to prevent splitting charges and uphold the accused’s right against double jeopardy.
    What is Article 365 of the Revised Penal Code? Article 365 addresses imprudence and negligence, defining reckless imprudence and outlining penalties for acts resulting in damage or injury due to a lack of precaution.
    What was the final ruling regarding Francis O. Morales? Francis O. Morales was found guilty of reckless imprudence resulting in multiple slight physical injuries and damage to property, sentenced to public censure for the injuries, and ordered to pay a fine for the property damage, along with temperate damages.
    What are temperate damages? Temperate damages are awarded when some pecuniary loss is evident but the exact amount cannot be precisely determined; they serve as a moderate compensation.
    What does the third paragraph of Article 365 state? The third paragraph of Article 365 of the RPC states the penalty, when the reckless act “resulted in damage to the property of another, the offender shall be punished by a fine ranging from an amount equal to the value of said damages to three (3) times such value, but which shall in no case be less than Five Thousand pesos (P5,000.00).”

    The Supreme Court’s decision in this case provides much-needed clarity on how to penalize reckless imprudence resulting in multiple consequences. By affirming the Ivler doctrine and rejecting the complexing of quasi-offenses, the Court has ensured that individuals who act negligently are held accountable for the full extent of the harm they cause. This ruling serves as a reminder of the importance of exercising caution and adhering to traffic laws, as the consequences of recklessness can be severe.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Francis O. Morales v. People, G.R. No. 240337, January 04, 2022

  • Bank’s Duty of Care: Liability for Counterfeit Currency and Customer Due Diligence

    The Supreme Court held that banks have a high duty of care to their depositors and can be held liable for damages if they release counterfeit currency. In this case, the Bank of the Philippine Islands (BPI) was found negligent for failing to list the serial numbers of US dollar bills withdrawn by a customer, leading to the circulation of counterfeit bills and causing embarrassment and financial loss to the customer. This decision underscores the banking industry’s responsibility to exercise the highest degree of diligence to protect customers from financial harm, including implementing measures to prevent the disbursement of counterfeit currency and maintaining thorough transaction records.

    Dollars and Distress: Can Banks Be Held Liable for Circulating Counterfeit Currency?

    This case revolves around the predicament of Spouses Fernando and Nora Quiaoit who, after withdrawing US$20,000 from their BPI account, encountered significant distress when some of the bills were rejected as counterfeit in Madrid. The central legal question is whether BPI exercised the required level of diligence in handling the currency withdrawal and whether the bank is liable for the damages suffered by the spouses as a result of the counterfeit bills.

    The Supreme Court addressed the core issue of BPI’s negligence in handling the transaction. The court emphasized the high standard of care required of banking institutions, citing Spouses Carbonell v. Metropolitan Bank and Trust Company, which states that banks are expected to uphold the highest standards of integrity and performance.

    “The General Banking Act of 2000 demands of banks the highest standards of integrity and performance. The Court ruled that banks are under obligation to treat the accounts of their depositors with meticulous care.”

    BPI’s failure to list the serial numbers of the dollar bills at the time of withdrawal was a critical point of contention. Although BPI marked the bills with a “chapa” to identify their origin, the Court found that this measure was insufficient. The Court argued that listing the serial numbers would have provided a definitive record to verify whether the counterfeit bills originated from the bank. This lack of diligence exposed both the client and the bank to potential risks and losses. The court pointed out that BPI had ample opportunity to prepare the dollar bills since Fernando informed BPI five days before the withdrawal.

    Furthermore, the Supreme Court affirmed the Court of Appeals’ ruling that BPI’s negligence was the proximate cause of the spouses Quiaoit’s losses. Proximate cause, in legal terms, refers to the cause that, in a natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, without which the result would not have occurred. The Court noted that the spouses Quiaoit lacked the expertise to verify the genuineness of the dollar bills and were not informed about the significance of the “chapa” markings. As such, they relied on BPI to ensure the currency’s authenticity.

    The Court also invoked the doctrine of last clear chance, further solidifying BPI’s liability. This doctrine suggests that even if the plaintiff (the spouses Quiaoit, in this case) was negligent, the defendant (BPI) could still be liable if it had the last opportunity to prevent the injury but failed to do so. The Court referred to the case of Allied Banking Corporation v. Bank of the Philippine Islands to explain the doctrine:

    “The doctrine of last clear chance, stated broadly, is that the negligence of the plaintiff does not preclude a recovery for the negligence of the defendant where it appears that the defendant, by exercising reasonable care and prudence, might have avoided injurious consequences to the plaintiff notwithstanding the plaintiff’s negligence.”

    In this context, the Court argued that BPI had the last clear chance to prevent the circulation of counterfeit bills by simply listing the serial numbers. Their failure to do so constituted a breach of their duty of care, making them liable for the resulting damages.

    Regarding damages, the Court upheld the award of moral damages to the spouses Quiaoit. Moral damages are awarded to compensate for mental anguish, suffering, and similar non-pecuniary losses. The Court referenced Pilipinas Bank v. Court of Appeals, which sustained the award of moral damages in a similar case, noting that the bank’s negligence caused serious anxiety, embarrassment, and humiliation to the respondents. The Court found that the spouses Quiaoit experienced significant distress due to the incident, justifying the award of moral damages. However, the Court deleted the award of exemplary damages, which are intended to serve as a warning, as there was no evidence of malice or bad faith on the part of BPI. The Court sustained the award of attorney’s fees, acknowledging that the spouses Quiaoit were compelled to litigate to protect their rights.

    FAQs

    What was the key issue in this case? The key issue was whether BPI exercised due diligence in handling the withdrawal of US dollar bills and whether it should be held liable for damages resulting from the circulation of counterfeit currency.
    What did the Court rule regarding BPI’s negligence? The Court ruled that BPI failed to exercise the highest degree of diligence required of banking institutions by not listing the serial numbers of the dollar bills, which was considered a breach of their duty of care.
    What is the doctrine of last clear chance, and how does it apply to this case? The doctrine of last clear chance states that a party with the final opportunity to prevent harm is liable if they fail to do so. BPI had the last clear chance to prevent the circulation of counterfeit bills but failed by not listing the serial numbers.
    What type of damages were awarded in this case? The Court awarded moral damages to compensate for the anxiety and humiliation suffered by the spouses Quiaoit and attorney’s fees because they were forced to litigate. The award for exemplary damages was deleted.
    Why was listing the serial numbers of the dollar bills important? Listing the serial numbers would have provided a definitive record to verify whether the counterfeit bills originated from BPI, which would have absolved the bank or confirmed its liability.
    What standard of care are banks held to in handling transactions? Banks are held to the highest degree of diligence and are expected to treat the accounts of their depositors with meticulous care, ensuring the authenticity and integrity of currency transactions.
    What is the significance of the “chapa” marking in this case? While BPI marked the bills with a “chapa” to identify their origin, the Court found it insufficient because the customer was not informed of the markings. This did not eliminate the need for further due diligence such as listing serial numbers.
    Can customers expect banks to guarantee the authenticity of currency they withdraw? Yes, customers can reasonably expect banks to guarantee the authenticity of the currency they withdraw, as banks have a high duty of care to ensure the accuracy and legitimacy of their transactions.

    In conclusion, this case serves as a crucial reminder of the stringent standards of care imposed on banks in their dealings with customers. It reinforces the importance of implementing robust procedures to prevent the circulation of counterfeit currency and to protect customers from financial losses and reputational damage.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: BANK OF THE PHILIPPINE ISLANDS VS. SPOUSES FERNANDO V. QUIAOIT, G.R. No. 199562, January 16, 2019

  • Employer’s Liability: Proving Negligence in Employee Conduct

    The Supreme Court has clarified the burden of proof in cases involving an employer’s liability for the negligent acts of their employees. The Court ruled that once a plaintiff proves an employee’s negligence occurred within the scope of their assigned tasks, the burden shifts to the employer to prove they exercised due diligence in selecting and supervising the employee. Failing to do so results in the employer being held solidarily liable for damages. This decision emphasizes the importance of employers actively demonstrating their commitment to ensuring their employees act responsibly and avoid negligence.

    Who’s Responsible? When a Driver’s Negligence Leads to Employer’s Liability

    In Raul S. Imperial v. Heirs of Neil Bayaban, and Mary Lou Bayaban, the central issue revolved around determining the extent of an employer’s liability for the negligent actions of their employee. On December 14, 2003, a van owned by Raul S. Imperial and driven by his employee, William Laraga, was involved in an accident with a tricycle, resulting in severe injuries to spouses Neil and Mary Lou Bayaban. The Bayaban Spouses sought compensation for their injuries, leading to a legal battle that reached the Supreme Court.

    The case hinged on Articles 2176 and 2180 of the Civil Code, which address quasi-delicts and vicarious liability. Article 2176 defines quasi-delict as fault or negligence causing damage to another in the absence of a pre-existing contractual relationship. Article 2180 extends this liability, holding employers responsible for the damages caused by their employees acting within the scope of their assigned tasks, even if the employer is not engaged in any business or industry. This responsibility ceases only when the employer proves they exercised the diligence of a good father of a family to prevent the damage.

    Article 2180. The obligation imposed by Article 2176 is demandable not only for one’s own acts or omissions, but also for those of persons for whom one is responsible. Employers shall be liable for the damages caused by their employees and household helpers acting within the scope of their assigned tasks, even though the former are not engaged in any business or industry.

    The legal principle of vicarious liability, as explained in Cangco v. Manila Railroad Co., imposes moral responsibility on employers for the negligence of their employees. However, this responsibility is limited to instances where the employee acts within the scope of their assigned tasks. An act is considered within the scope of employment if it is done by an employee in furtherance of the interests of the employer or for the account of the employer at the time of the injury or damage.

    The Supreme Court, in this case, determined that the Bayaban Spouses successfully demonstrated that Laraga was acting within the scope of his employment at the time of the accident. The accident occurred at 3:00 p.m. in Antipolo City, where Imperial’s greenhouse and garden were located. This supported the conclusion that Laraga was driving the van in connection with the maintenance of Imperial’s property. The Court dismissed Imperial’s defense that Sunday was Laraga’s day off due to the lack of supporting evidence.

    Building on this, the Court clarified that once the plaintiff establishes the employer-employee relationship and that the employee was acting within the scope of their assigned tasks, a presumption arises that the employer was negligent in the selection and supervision of the employee. It is then up to the employer to present evidence to rebut this presumption by showing they exercised the diligence of a good father of a family. In this instance, Imperial failed to provide sufficient evidence to prove that he exercised due diligence in the selection and supervision of Laraga. His self-serving testimonies about financing Laraga’s driving lessons were not supported by documentary proof.

    Furthermore, the Court addressed Imperial’s claim that the official receipts for medical and hospital bills were not competent evidence of actual damages due to a lack of authentication. The Court noted that while official receipts are private documents and must be authenticated, this can be achieved by presenting a witness who saw the document executed or written, or by providing evidence of the genuineness of the signature or handwriting of the maker. Mary Lou Bayaban’s testimony regarding the circumstances of the accident and the expenses incurred, along with the presentation of the original receipts, constituted sufficient authentication.

    Additionally, the Court reinstated the award of temperate damages for the loss of earning capacity. Temperate damages are awarded when some pecuniary loss has been suffered, but its amount cannot be proved with certainty. Even though the Bayaban Spouses could not provide definitive proof of income lost during their incapacitation, they were still entitled to compensation for their inability to work. The Court clarified that these damages were distinct from the actual damages awarded for medical expenses.

    FAQs

    What was the key issue in this case? The key issue was determining the extent of an employer’s liability for the negligent actions of their employee, specifically whether the employee was acting within the scope of their assigned tasks at the time of the accident.
    What are Articles 2176 and 2180 of the Civil Code? Article 2176 defines quasi-delict as fault or negligence causing damage to another. Article 2180 extends this liability, holding employers responsible for the damages caused by their employees acting within the scope of their assigned tasks.
    What does it mean for an employee to be acting within the scope of their assigned tasks? An act is considered within the scope of employment if it is done by an employee in furtherance of the interests of the employer or for the account of the employer at the time of the injury or damage.
    Who has the burden of proof in establishing the employer’s liability? The plaintiff must first prove the existence of an employer-employee relationship and that the employee was acting within the scope of their assigned tasks. Once these are established, the burden shifts to the employer to prove they exercised due diligence in selecting and supervising the employee.
    What constitutes due diligence in the selection and supervision of an employee? Due diligence requires an employer to take reasonable steps to ensure that their employees are competent and capable of performing their assigned tasks without negligence. This may include providing training, conducting background checks, and implementing safety protocols.
    What is the difference between actual and temperate damages? Actual damages are compensation for losses that can be proven with certainty, such as medical expenses. Temperate damages are awarded when some pecuniary loss has been suffered, but its amount cannot be proved with certainty.
    What is the significance of original receipts in proving damages? Original receipts are considered the best evidence of actual damages incurred. While they are private documents that require authentication, the testimony of the person to whom the receipts were issued can serve as sufficient authentication.
    Can an employer be held liable even if the employee’s negligence occurred outside of regular working hours? Yes, if the employee was still acting within the scope of their assigned tasks at the time of the negligence. In this case, the fact that the accident occurred on a Sunday did not absolve the employer of liability because the employee was still furthering the employer’s interests.

    This case serves as a crucial reminder to employers about the extent of their liability for the actions of their employees. By understanding the burden of proof and the importance of exercising due diligence in the selection and supervision of employees, employers can take steps to mitigate their risk and avoid potential liability.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: RAUL S. IMPERIAL, VS. HEIRS OF NEIL BAYABAN, G.R. No. 197626, October 03, 2018

  • Employer’s Liability: Establishing Negligence in Employee Actions

    The Supreme Court clarified that an employer is solidarily liable for damages caused by an employee’s negligence if the negligent act was performed within the scope of their assigned tasks. The injured party must first prove that the employee was acting within their assigned tasks. Once proven, the burden shifts to the employer to prove they exercised due diligence in selecting and supervising the employee. Failure to prove this diligence results in the employer being held liable for the employee’s actions.

    Whose Task Is It Anyway? Determining Employer Liability in a Vehicular Accident

    This case revolves around a vehicular accident involving a van owned by Raul S. Imperial and driven by his employee, William Laraga, and a tricycle carrying spouses Neil and Mary Lou Bayaban. The accident resulted in severe injuries to the Bayaban spouses, leading them to file a complaint for damages against Imperial, Laraga, and the tricycle driver. The central legal question is whether Imperial, as the employer, is liable for the negligent acts of his employee, Laraga. This determination hinges on whether Laraga was acting within the scope of his employment at the time of the accident and whether Imperial exercised due diligence in the selection and supervision of his employee.

    The legal framework for this case is based on **Articles 2176 and 2180 of the Civil Code**. Article 2176 defines quasi-delict, which is fault or negligence causing damage to another without a pre-existing contractual relationship. Article 2180 extends this liability, holding employers responsible for the damages caused by their employees acting within the scope of their assigned tasks, even if the employer is not engaged in any business or industry.

    Article 2180. The obligation imposed by Article 2176 is demandable not only for one’s own acts or omissions, but also for those of persons for whom one is responsible.

    Employers shall be liable for the damages caused by their employees and household helpers acting within the scope of their assigned tasks, even though the former are not engaged in any business or industry.

    The responsibility treated of in this article shall cease when the persons herein mentioned prove that they observed all the diligence of a good father of a family to prevent damage.

    The Supreme Court emphasized that the burden of proof lies with the plaintiff to demonstrate that the employee was indeed acting within the scope of their assigned tasks at the time of the negligent act. Citing the Latin maxim “*ei incumbit probatio qui dicit, non qui negat*,” the Court reiterated that “he who asserts, not he who denies, must prove.” Once this is established, a presumption arises that the employer was negligent in the selection and supervision of the employee. This presumption is disputable, meaning the employer can present evidence to show they exercised due diligence.

    In this case, Imperial admitted that Laraga was his employee, a fact that was not in dispute. The critical point was whether Laraga was acting within the scope of his duties when the accident occurred. The Court found that the Bayaban spouses presented sufficient evidence to suggest that Laraga was acting within his assigned tasks. The accident happened at 3:00 p.m. in Antipolo City, where Imperial admitted to owning a greenhouse and garden. Imperial had claimed he loaned the van to another person for maintenance of that same greenhouse, implying Laraga was operating the van in connection with Imperial’s property.

    Imperial’s defense that Sunday was Laraga’s day off was deemed unconvincing due to the lack of supporting evidence. Because the respondents successfully demonstrated that Laraga was acting within the scope of his employment, the burden shifted to Imperial to prove that he exercised due diligence in the selection and supervision of Laraga. He attempted to prove this by stating that he financed Laraga’s formal driving lessons, but he failed to provide documentary proof to support this claim. The Court deemed this insufficient to overturn the presumption of negligence.

    The Court also addressed the admissibility of the official receipts for medical and hospital expenses. Imperial argued that these receipts were not properly authenticated and, therefore, should not be considered as evidence of actual damages. The Court clarified that under the rules of evidence, official receipts are considered private documents. To be admitted as evidence, private documents must be authenticated, either by presenting a witness who saw the document executed or by providing evidence of the genuineness of the signature.

    The Court found that Mary Lou Bayaban’s testimony regarding the circumstances of the accident and the expenses incurred was sufficient authentication. She testified that the official receipts were issued to her and her husband upon payment of the expenses. The Court deemed her testimony competent evidence of the execution of the official receipts, making them admissible as proof of the actual damages sustained by the Bayaban spouses.

    Furthermore, the Court reinstated the award of temperate damages, which the Court of Appeals had previously deleted. Temperate damages are awarded when some pecuniary loss is proven, but the exact amount cannot be determined with certainty. The Court found that despite the lack of specific proof of lost income, the Bayaban spouses suffered a pecuniary loss due to their inability to work as a seaman and a pharmacist, respectively. The Court reasoned that temperate and actual damages covered distinct pecuniary losses—temperate damages for loss of earning capacity and actual damages for medical and hospital expenses.

    In conclusion, the Supreme Court affirmed the decision of the Court of Appeals with a modification to reinstate the award for temperate damages, holding Imperial solidarily liable with his employee for the damages sustained by the Bayaban spouses. This case underscores the importance of employers exercising due diligence in the selection and supervision of their employees. It also clarifies the evidentiary requirements for proving damages in quasi-delict cases.

    FAQs

    What was the key issue in this case? The key issue was whether an employer is liable for the negligent acts of their employee when the employee is acting within the scope of their assigned tasks. The case also addresses the level of diligence an employer must exercise in the selection and supervision of their employees.
    What are the key legal provisions involved? The relevant legal provisions are Articles 2176 and 2180 of the Civil Code, which define quasi-delict and establish vicarious liability for employers. These articles outline the conditions under which an employer can be held responsible for the negligent acts of their employees.
    Who has the burden of proof in these cases? The plaintiff initially has the burden of proving that the employee was acting within the scope of their assigned tasks at the time of the negligent act. Once this is proven, the burden shifts to the employer to prove that they exercised due diligence in the selection and supervision of the employee.
    What constitutes ‘due diligence’ in selecting and supervising employees? ‘Due diligence’ is understood as the diligence of a good father of a family in preventing damage, meaning reasonable steps to ensure the employee is competent and well-supervised. Providing documentary proof that the employee underwent formal driving lessons is a better proof of ‘due diligence’.
    How are damages proven in quasi-delict cases? Damages are proven through the presentation of relevant evidence, such as official receipts for medical expenses and testimony regarding loss of income. While official receipts are considered private documents, they can be authenticated through witness testimony regarding their execution and issuance.
    What are temperate damages, and when are they awarded? Temperate damages are awarded when some pecuniary loss has been suffered, but the amount cannot be proven with certainty. They are more than nominal but less than actual or compensatory damages and are intended to provide a reasonable compensation under the circumstances.
    Can temperate and actual damages be awarded in the same case? Yes, temperate and actual damages can be awarded in the same case if they cover distinct pecuniary losses. Actual damages may cover tangible expenses like medical bills, while temperate damages may compensate for intangible losses like loss of earning capacity.
    Is an employer automatically liable for the actions of their employee? No, an employer is not automatically liable. Liability depends on whether the employee was acting within the scope of their assigned tasks and whether the employer exercised due diligence in the selection and supervision of the employee.

    This case serves as a clear reminder of the responsibilities employers have regarding their employees’ actions. By requiring employers to prove they exercised due diligence, the Supreme Court reinforces the importance of proper hiring and supervision practices to prevent negligence and protect the public. Employers must take proactive steps to ensure their employees are well-trained and supervised to avoid potential liability.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: RAUL S. IMPERIAL v. HEIRS OF NEIL BAYABAN, G.R. No. 197626, October 03, 2018

  • Libel and Damages: Balancing Free Speech and Reputation in Philippine Law

    In a libel case, the Supreme Court clarified the requirements for awarding damages, emphasizing the need for concrete evidence linking the defamatory statement to actual harm suffered by the plaintiff. While affirming the conviction for libel, the Court adjusted the damages awarded, underscoring the balance between protecting freedom of the press and ensuring redress for reputational damage. This ruling highlights the importance of responsible journalism and the need for plaintiffs to substantiate claims of financial or emotional distress resulting from libelous statements.

    Raffy Tulfo’s Article: Did It Cross the Line from Journalism to Libel?

    This case originated from an article written by Raffy Tulfo in Abante Tonite, implicating Michael C. Guy in tax fraud and alleging that then Department of Finance Secretary Juanita Amatong intervened in the investigation. Guy claimed the article damaged his reputation, leading to business losses and personal distress, and subsequently filed a libel case against Tulfo and the newspaper’s representatives. The Regional Trial Court (RTC) initially found the respondents guilty of libel and awarded substantial damages. However, the Court of Appeals (CA) affirmed the conviction but modified the damages, deleting the award for actual damages due to lack of evidence. Guy then appealed to the Supreme Court, seeking reinstatement of the RTC’s original judgment.

    The central legal question before the Supreme Court was whether there was sufficient basis to justify the award of actual, moral, and exemplary damages to Guy. In Philippine law, libel is defined as a public and malicious imputation of a crime, vice, or defect, which tends to cause dishonor or discredit to another. To be actionable, the statement must be defamatory, malicious, given publicity, and identifiable as referring to the plaintiff.

    The Supreme Court reiterated that a criminal case involves both criminal and civil aspects, with the offended party having a right to claim civil liability arising from the crime. However, the Court emphasized that the interest of the private offended party is limited to the civil liability, and only the State, through the Office of the Solicitor General, can appeal the criminal aspect of the case. Thus, Guy’s appeal was limited to questioning the amount of damages awarded.

    Regarding actual damages, the Court explained that these damages compensate for injuries that restore the injured party to their position before the injury occurred, pertaining to losses that are actually sustained and measurable. Article 2199 of the Civil Code states that adequate compensation is only for such pecuniary loss suffered by him as he has duly proved. The Supreme Court emphasized that actual damages must be proven with a reasonable degree of certainty, based on competent proof, and cannot be based on flimsy, remote, or speculative evidence.

    Except as provided by law or by stipulation, a party is entitled to adequate compensation only for such pecuniary loss as is duly proven. Basic is the rule that to recover actual damages, not only must the amount of loss be capable of proof; it must also be actually proven with a reasonable degree of certainty, premised upon competent proof or the best evidence obtainable.

    In this case, the Court found that Guy failed to substantiate his claim for actual damages. His allegation of potentially earning P50,000,000.00 in ten years was deemed a mere assumption without any foundation, insufficient to prove that he had lost P5,000,000.00 in earnings. The Court noted that the award of unrealized profits cannot be based solely on the testimony of the claiming party.

    The Court distinguished actual damages from temperate damages, which may be awarded when some pecuniary loss is proven, but the amount cannot be determined with exact certainty. However, Guy also failed to prove that he suffered any pecuniary loss, as the one client he allegedly lost due to the article resumed transacting with him in 2005.

    Concerning moral damages, the Court recognized that these damages compensate for mental pain and suffering resulting from a wrong. Article 2219 of the Civil Code specifically allows for the recovery of moral damages in cases of libel or defamation. The amount of moral damages depends on the circumstances of each case, and courts have discretion in fixing the amount, as long as there is a sufficient basis for awarding such damages.

    Moral damages may be recovered in the following and analogous cases: Libel, slander or any other form of defamation.

    The Court clarified that moral damages may be awarded even without proof of pecuniary loss, provided that the injury resulted from the offending party’s action. However, the claimant must sufficiently prove the factual foundation of the award and the causal connection of their suffering to the respondent’s act. The Court stated that moral damages are designed to compensate the claimant for actual injury suffered, not to impose a penalty on the wrongdoer.

    While Guy claimed social humiliation and anxiety from the libelous article, the Court found that he failed to present sufficient evidence supporting his assertions. He submitted no evidence substantiating his claimed loss or the alleged tainting of his reputation. However, the Court acknowledged that Guy’s family members were displeased with him due to the accusations, and his children were questioned at school. As such, an award of P500,000.00 as moral damages was deemed an adequate recompense for the mental anguish and wounded feelings endured by Guy.

    Regarding exemplary damages, the Court clarified that contrary to the Court of Appeals’ interpretation, exemplary damages may be awarded even in the absence of aggravating circumstances, particularly when the offender’s conduct is highly reprehensible or outrageous. Exemplary damages serve as an example or correction for the public good and are imposed as a punishment for highly reprehensible conduct, preventing the repetition of socially deleterious actions.

    The Court cited the requirements for awarding exemplary damages, including that the claimant must first establish their right to moral, temperate, liquidated, or compensatory damages, and the wrongful act must be accompanied by bad faith. The Court found that the respondents published the libelous article without verifying the truth of the allegations against Guy, who was not a government official under the Revenue Integrity Protection Service’s jurisdiction. This lack of verification demonstrated a reckless disregard for the truth, warranting the imposition of exemplary damages. Therefore, the Court directed the respondents to pay Guy exemplary damages in the amount of P1,000,000.00 to ensure that such conduct would not be repeated.

    The Supreme Court emphasized the importance of responsible journalism, especially in the age of modern technology where news can be rapidly disseminated through social media. The Court noted that journalists have a responsibility to shape the news accurately and fairly, adhering to ethical standards. This case serves as a reminder to media practitioners to exercise caution and verify information before publishing, to avoid reckless disregard for the truth.

    FAQs

    What was the key issue in this case? The key issue was whether the awarded damages for libel were justified and properly computed, considering the evidence presented by the plaintiff, Michael C. Guy. The Court evaluated the appropriateness of actual, moral, and exemplary damages.
    What are actual damages and how are they proven? Actual damages are compensation for tangible losses directly resulting from the defendant’s actions, such as lost income or business opportunities. They must be proven with a reasonable degree of certainty through documentary evidence or other concrete proof.
    What are moral damages and when can they be awarded? Moral damages are awarded for mental anguish, suffering, and similar intangible injuries resulting from the defendant’s actions, like libel. They can be awarded even without proof of pecuniary loss, as long as there’s evidence of the plaintiff’s suffering due to the libelous statement.
    What are exemplary damages and what purpose do they serve? Exemplary damages are punitive damages intended to set an example and deter similar conduct in the future, particularly in cases of gross negligence or malicious intent. They are not a matter of right and are awarded at the court’s discretion.
    What role does freedom of the press play in libel cases? Freedom of the press is a constitutionally protected right, but it is not absolute and must be exercised responsibly. Journalists must ensure the accuracy of their reporting and avoid reckless disregard for the truth to prevent libel.
    What must a plaintiff prove in a libel case to be awarded damages? A plaintiff must prove that the statement was defamatory, published or communicated to a third party, refers to the plaintiff, and is malicious. Additionally, they must provide evidence linking the defamatory statement to specific damages claimed.
    How did the Court balance the protection of reputation with freedom of the press in this case? The Court balanced these interests by affirming the conviction for libel, recognizing the harm caused to the plaintiff’s reputation, while also scrutinizing the evidence for damages, ensuring awards were based on proven harm and not speculation. This approach seeks to uphold responsible journalism while providing redress for reputational injuries.
    Why was the initial award of actual damages overturned? The initial award of actual damages was overturned because the plaintiff failed to provide sufficient evidence to substantiate his claim of financial loss directly resulting from the libelous article. His testimony alone was deemed insufficient.

    This case underscores the delicate balance between freedom of the press and the protection of individual reputation. While journalists have the right to report on matters of public interest, they must do so responsibly and with due diligence to avoid causing unwarranted harm. Plaintiffs seeking damages for libel must provide concrete evidence to support their claims.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Michael C. Guy vs. Raffy Tulfo, G.R. No. 213023, April 10, 2019

  • Quasi-Delict and Proximate Cause: Establishing Negligence in Property Damage Claims

    In VDM Trading, Inc. v. Leonita Carungcong, the Supreme Court affirmed the Court of Appeals’ decision, dismissing a complaint for damages due to lack of evidence establishing a quasi-delict. The Court emphasized that to successfully claim damages based on negligence, the plaintiff must sufficiently prove the damage suffered, the defendant’s fault or negligence, and the direct causal link between the act and the damage. This ruling highlights the importance of concrete evidence and the difficulties in attributing liability for property damage without clearly demonstrating fault and causation.

    Water Woes: Can a Condo Owner Be Liable for a Neighbor’s Leaks?

    The case arose from a complaint filed by VDM Trading, Inc. and Spouses Luis and Nena Domingo against Leonita Carungcong and Wack Wack Twin Towers Condominium Association, Inc. The Domingos claimed that water leakage from Carungcong’s unit above theirs caused significant damage to their property. They alleged that unauthorized plumbing work on Carungcong’s balcony, leased by Hak Yek Tan, was the source of the leak. Further, they asserted that the condominium association was negligent in failing to prevent the unauthorized alterations. The central legal question was whether the Domingos could prove the elements of a quasi-delict to hold Carungcong and the association liable for the damage.

    The Regional Trial Court (RTC) initially ruled in favor of the Domingos, holding Carungcong liable for actual damages and legal fees. The RTC later modified its decision to include the condominium association, Wack Wack, as solidarily liable. However, the Court of Appeals (CA) reversed the RTC’s decision, finding insufficient evidence to support the claim that the plumbing work caused the damage. The CA also noted a prior case where the Housing and Land Use Regulatory Board (HLURB) found Golden Dragon, the condominium developer, liable for the leaks due to defective construction. This existing finding significantly weakened the Domingos’ case against Carungcong and Wack Wack.

    The Supreme Court, in its analysis, underscored the importance of establishing the elements of a quasi-delict under Article 2176 of the Civil Code. This article states:

    Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict.

    The Court emphasized that a quasi-delict requires proof of damage suffered by the plaintiff, fault or negligence on the part of the defendant, and a direct causal connection or proximate cause between the act and the damage. The Court found that the Domingos failed to sufficiently prove these elements.

    Regarding the extent of the damage, the Court noted that the evidence presented was insufficient. The photographs only depicted damage in one room, and the letter-quotation from M. Laher Construction, intended to prove the full extent of the damage, was deemed inadmissible due to lack of proper identification and authentication. Citing Section 20, Rule 132 of the Rules of Court, the Court explained that the identity and authenticity of a private document must be properly established. This requires either a witness who saw the execution of the document or someone who can testify to the genuineness of the signature or handwriting.

    Furthermore, the Court addressed the admissibility of the sister’s (Lagman-Castillo) handwritten report and testimony of their attorney, Atty. Villareal. The Court ruled that testimony regarding observations from Lagman-Castillo’s report was inadmissible hearsay because Atty. Villareal lacked personal knowledge of the facts. The Court explained that under the rules of evidence, a witness may only testify to facts they have personal knowledge of, derived from their own perception. This underscores the importance of presenting direct witnesses with firsthand knowledge of the events.

    The Court also found no evidence of fault or negligence on the part of Carungcong or the condominium association. The Domingos failed to demonstrate that the plumbing work was illegal or negligently performed. The Court emphasized that the burden of proof lies with the plaintiff to establish negligence, and the Domingos did not meet this burden. The Court further noted that, under the Amended Master Deed, the condominium association’s responsibility was limited to the common areas, and the unit owners were responsible for the maintenance and repair of their units.

    Finally, the Court found that the Domingos failed to establish proximate cause between the plumbing work and the damage. The Court found it illogical that a leak isolated to the balcony area would cause widespread damage throughout the unit. Moreover, the prior HLURB case finding Golden Dragon liable for defective construction further weakened the Domingos’ claim that the plumbing work was the cause of the damage. The Court stated that it could not ignore the contents of the HLURB complaint, even if it was offered for a different purpose, because it formed part of the records of the case.

    The Supreme Court reiterated that proximate cause requires a direct and unbroken sequence between the defendant’s action and the plaintiff’s injury. In this case, the Court found that the Domingos failed to establish this direct link, and the prior HLURB decision pointed to a different cause altogether: defective construction. This ruling underscores the stringent requirements for proving causation in quasi-delict cases, especially when other potential causes exist.

    FAQs

    What is a quasi-delict? A quasi-delict is an act or omission that causes damage to another, where there is fault or negligence but no pre-existing contractual relationship between the parties. It is a basis for claiming damages under Philippine law.
    What are the elements of a quasi-delict? The elements are: (1) damage suffered by the plaintiff, (2) fault or negligence of the defendant, and (3) a causal connection between the act and the damage, also known as proximate cause. All three elements must be proven to establish liability.
    What does “proximate cause” mean? Proximate cause is the direct and natural sequence of events, unbroken by any efficient intervening cause, that leads to the injury. It means the damage would not have occurred without the defendant’s action.
    Why was the letter-quotation from M. Laher not admitted as evidence? The letter-quotation was considered inadmissible because its identity and authenticity were not properly established. The petitioners failed to present a witness who could testify to its execution or the genuineness of the signatures.
    Why was the sister’s handwritten report considered hearsay? The testimony regarding the sister’s handwritten report was ruled as hearsay because the witness testifying (Atty. Villareal) did not have personal knowledge of the facts contained in the report. The sister herself needed to testify to the report’s accuracy.
    What was the significance of the prior HLURB case? The prior HLURB case, which found the condominium developer liable for the water leaks due to defective construction, weakened the petitioners’ claim that the plumbing work was the cause of the damage. It suggested an alternative cause for the damage.
    Who has the burden of proof in a quasi-delict case? In a quasi-delict case, the plaintiff has the burden of proving the defendant’s fault or negligence. The plaintiff must present evidence to establish that the defendant’s actions caused the damage.
    What is the role of the condominium association in maintaining the units? According to the Amended Master Deed, the condominium association’s responsibility is generally limited to the common areas. Unit owners are typically responsible for the maintenance and repair of their own units.

    The Supreme Court’s decision in VDM Trading, Inc. v. Leonita Carungcong serves as a reminder of the importance of thoroughly documenting and proving each element of a quasi-delict in property damage cases. Parties seeking damages must present concrete evidence to demonstrate the damage suffered, the defendant’s fault or negligence, and the direct causal link between the act and the damage. Failure to do so may result in the dismissal of the claim.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: VDM Trading, Inc. v. Leonita Carungcong, G.R. No. 206709, February 06, 2019

  • Carrier’s Duty: Determining Damages for Maritime Negligence

    In the case of Sulpicio Lines, Inc. v. Major Victorio Karaan, the Supreme Court affirmed the Court of Appeals’ decision, holding Sulpicio Lines liable for damages resulting from the sinking of the M/V Princess of the Orient. The Court clarified the standards for awarding temperate and exemplary damages in maritime incidents, emphasizing that common carriers must exercise extraordinary diligence for the safety of passengers. This ruling underscores the responsibility of shipping companies to ensure safe travel and provides guidance on compensation for victims of maritime negligence.

    Navigating Negligence: When a Ship Sinks, Who Pays the Price?

    The tragic sinking of the M/V Princess of the Orient on September 18, 1998, spawned numerous legal battles, including this case involving passengers Major Victorio Karaan, Spouses Napoleon and Herminia Labrague, and Ely Liva. These individuals, having survived the ill-fated voyage, sought damages from Sulpicio Lines, Inc. (now Philippine Span Asia Carrier Corporation) for breach of contract of carriage. The central legal question revolved around the propriety of awarding temperate and exemplary damages, given the circumstances surrounding the maritime disaster.

    The respondents claimed actual, moral, exemplary, and nominal damages, citing the trauma and losses they suffered during the sinking. During the trial, each respondent recounted their harrowing experiences, detailing the lack of assistance from the ship’s crew and the chaotic scene as the vessel went down. Major Karaan described the terrifying moments of being submerged and his subsequent rescue after 15 hours in the water. Napoleon and Herminia Labrague recounted the loss of their daughter, Karen Hope, whose lifeless body was later recovered. Ely Liva corroborated their accounts, emphasizing the panic and confusion that ensued.

    In its defense, Sulpicio Lines presented testimonies from its employees to establish that the vessel was seaworthy and that proper procedures were followed. Nelson Sato, the second mate, testified about the vessel’s equipment and pre-departure inspections. Atty. Geraldine Jorda, the Personnel Officer, vouched for Captain Esrum Mahilum’s competence. Engr. Perry Chan, the Third Engineer, testified about the engine’s condition. Edgar Samson, the Radio Operator, detailed weather reports and communication efforts. Captain Anito Alfajardo from the Philippine Coastguard affirmed the vessel’s clearance for departure. Salvacion Buaron, the Vice-President for passenger service of SLI, stated the assistance provided to the victims. Despite these testimonies, the Regional Trial Court (RTC) and subsequently the Court of Appeals (CA) found Sulpicio Lines liable.

    The RTC initially awarded actual, moral, exemplary, and nominal damages. However, upon appeal, the CA modified the award, replacing actual damages with temperate damages due to insufficient proof of the exact amounts of loss. The CA also upheld the award of exemplary damages, finding that Sulpicio Lines had acted recklessly. The Supreme Court, in its review, affirmed the CA’s decision, emphasizing the importance of extraordinary diligence required of common carriers.

    The Supreme Court addressed the issue of temperate damages, clarifying that they are appropriate when pecuniary loss is evident, but its exact amount cannot be proven with certainty. Article 2224 of the Civil Code supports this principle, stating:

    Article 2224. Temperate or moderate damages, which are more than nominal but less than compensatory damages, may be recovered when the court finds that some pecuniary loss has been suffered but its amount cannot, from the nature of the case, be provided with certainty.

    The Court found no error in the CA’s imposition of temperate damages, as the respondents demonstrably suffered losses, even though they could not provide precise documentation. This recognition of temperate damages serves as a vital safety net for victims who experience genuine losses without the ability to substantiate every detail with receipts or documents.

    Moreover, the Supreme Court delved into the propriety of awarding exemplary damages, which are governed by Articles 2229, 2232, 2233 and 2234 of the Civil Code:

    Article. 2229. Exemplary or corrective damages are imposed, by way of example or correction for the public good, in addition to the moral, temperate, liquidated or compensatory damages.

    Article. 2232. In contracts and quasi-contracts, the court may award exemplary damages if the defendant acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner.

    The Court concurred with the CA’s assessment that Sulpicio Lines’ negligence warranted exemplary damages. The failure to exercise extraordinary diligence, coupled with the Captain’s erroneous maneuvers, constituted recklessness. Citing Sulpicio Lines, Inc. v. Sesante et. al., the Court reiterated that exemplary damages serve to reshape socially harmful behavior by creating deterrents.

    Clearly, the petitioner and its agents on the scene acted wantonly and recklessly. Wanton and reckless are virtually synonymous in meaning as respects liability for conduct towards others. Wanton means characterized by extreme recklessness and utter disregard for the rights of others; or marked by or manifesting arrogant recklessness of justice or of rights or feelings of others. Conduct is reckless when it is an extreme departure from ordinary care, in a situation in which a high degree of danger is apparent.

    The Court emphasized that the shipping company’s crew failed to undertake proper stability calculations, prepare a detailed cargo stowage plan, and transmit an SOS message through the appropriate channels. Such failures highlighted a disregard for safety and a breach of the extraordinary diligence required of common carriers. These shortcomings ultimately contributed to the tragic loss of life and justified the imposition of exemplary damages.

    The decision serves as a reminder to common carriers of their duty to prioritize passenger safety. Extraordinary diligence entails not only ensuring the seaworthiness of vessels but also implementing rigorous safety protocols and adequately training crew members. The consequences of failing to meet these standards can be severe, both in terms of legal liability and the immeasurable cost of human lives.

    Finally, the Supreme Court modified the interest rate applicable to the monetary awards, imposing a rate of six percent (6%) per annum from the date of the decision’s finality until full payment. This adjustment reflects the guidelines established in Eastern Shipping Lines, Inc. v. CA, as modified by Nacar v. Gallery Frames, et al.

    FAQs

    What was the key issue in this case? The key issue was whether the Court of Appeals correctly awarded temperate and exemplary damages to the respondents for the sinking of the M/V Princess of the Orient. The Supreme Court examined whether the actions of Sulpicio Lines warranted such damages under the Civil Code.
    What are temperate damages? Temperate damages are awarded when the court acknowledges that a pecuniary loss has occurred, but the exact amount cannot be proven with certainty. They are more than nominal damages but less than compensatory damages, offering a middle ground when precise quantification is impossible.
    What are exemplary damages? Exemplary damages are imposed as a form of punishment or correction for the public good, in addition to other forms of damages. In contract and quasi-contract cases, they are awarded if the defendant acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner.
    What is the standard of care for common carriers? Common carriers are required to exercise extraordinary diligence for the safety of their passengers. This high standard of care includes ensuring the seaworthiness of vessels, implementing rigorous safety protocols, and adequately training crew members to handle emergencies.
    What did Sulpicio Lines fail to do in this case? Sulpicio Lines failed to exercise extraordinary diligence by neglecting to perform proper stability calculations, prepare a detailed cargo stowage plan, and transmit an SOS message through internationally accepted channels. The Captain’s erroneous maneuvers also contributed to the sinking.
    Why was the award of actual damages replaced with temperate damages? The Court of Appeals replaced the award of actual damages with temperate damages because the respondents could not provide sufficient documentary evidence, such as receipts, to prove the exact amounts of their losses. However, the loss itself was evident.
    What does it mean to act wantonly or recklessly? To act wantonly means to exhibit extreme recklessness and utter disregard for the rights of others. Reckless conduct involves an extreme departure from ordinary care in a situation where a high degree of danger is apparent, indicating more than mere negligence.
    What was the interest rate imposed on the monetary awards? The Supreme Court imposed an interest rate of six percent (6%) per annum on the total amount of monetary awards. The interest rate is computed from the date of the decision’s finality until full payment, aligning with established legal guidelines.

    This case illustrates the judiciary’s commitment to holding common carriers accountable for ensuring passenger safety and providing appropriate compensation for losses suffered due to negligence. The ruling reinforces the importance of adhering to safety standards and exercising due diligence in maritime operations. The determination of damages, including temperate and exemplary awards, serves both to compensate victims and to deter future misconduct.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Sulpicio Lines, Inc. v. Major Victorio Karaan, G.R. No. 208590, October 3, 2018

  • Quasi-Delict and Double Recovery: Understanding Independent Civil Actions in Philippine Law

    In a decision clarifying the interplay between criminal and civil liabilities, the Supreme Court held that a counterclaim based on quasi-delict, filed in response to a civil action, does not require a prior reservation in a related criminal case. This ruling emphasizes that independent civil actions, such as those arising from quasi-delicts, can proceed separately from criminal actions, provided there is no double recovery of damages. The case underscores the importance of understanding the distinct nature of civil liabilities and the procedural rules governing their enforcement.

    Collision Course: Navigating Civil and Criminal Liabilities in a Vehicular Accident

    The case of Supreme Transportation Liner, Inc. v. Antonio San Andres arose from a vehicular accident involving a bus owned by Supreme Transportation Liner, Inc. (Supreme) and a bus owned by Antonio San Andres. Following the incident, San Andres filed a civil case for damages against Supreme. In response, Supreme filed a counterclaim alleging that the accident was caused by the negligence of San Andres’ driver. Crucially, Supreme had also filed a criminal complaint against San Andres’ driver but did not reserve the right to file a separate civil action in that criminal case.

    The Regional Trial Court (RTC) dismissed Supreme’s counterclaim, reasoning that because Supreme had not reserved the right to file a separate civil action in the criminal case, allowing the counterclaim would amount to double recovery of damages. The Court of Appeals (CA) affirmed the RTC’s decision. The appellate court agreed that Supreme’s failure to reserve the civil aspect of the criminal case precluded them from pursuing a separate civil action based on Article 2176 of the Civil Code, which governs quasi-delicts.

    The Supreme Court disagreed with both lower courts, holding that the RTC and CA incorrectly applied the rules on reservation of civil actions. The Court emphasized that Supreme’s counterclaim was based on a quasi-delict, specifically invoking Articles 2176, 2180, and 2184 of the Civil Code. These provisions address the responsibility for damages caused by negligence or fault, independent of any criminal liability.

    Article 2176. Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter.

    Building on this principle, the Court clarified that the requirement for reserving a civil action no longer applies to independent civil actions under Articles 32, 33, 34, and 2176 of the Civil Code. These actions may be filed at any time, provided the plaintiff does not recover twice for the same act or omission.

    The Supreme Court noted that by the time the RTC rendered its judgment in 2008, the Rules of Court had been revised to eliminate the reservation requirement for independent civil actions. As the Court stated in Casupanan v. Laroya:

    Under Section 1 of the present Rule 111, what is “deemed instituted” with the criminal action is only the action to recover civil liability arising from the crime or ex-delicto. All the other civil actions under Articles 32, 33, 34 and 2176 of the Civil Code are no longer “deemed instituted,” and may be filed separately and prosecuted independently even without any reservation in the criminal action. The failure to make a reservation in the criminal action is not a waiver of the right to file a separate and independent civil action based on these articles of the Civil Code.

    This approach contrasts with the previous rule, which required reservation to prevent the civil action from being impliedly instituted with the criminal action. The revised rule recognizes the distinct nature of independent civil actions and allows them to proceed separately to ensure that injured parties have adequate recourse for damages.

    However, the Court also cautioned against double recovery. Article 2177 of the Civil Code and Section 3, Rule 111 of the Rules of Court explicitly prohibit recovering damages twice for the same act or omission. Even though Supreme’s counterclaim was allowed to proceed, they would need to demonstrate that they had not already recovered damages in the criminal case against San Andres’ driver.

    The case was remanded to the RTC to allow Supreme the opportunity to present evidence on their counterclaim, subject to the prohibition against double recovery of damages. This outcome underscores the importance of carefully considering the nature of the civil action and complying with the applicable procedural rules.

    The Supreme Court ruling in this case serves as a reminder that an act or omission can give rise to both criminal and civil liabilities. A person found liable may be subject to civil liability ex delicto arising from the crime itself, and independent civil liabilities, such as those based on quasi-delict under Article 2176 of the Civil Code. The injured party can pursue either or both of these avenues, but cannot recover damages twice for the same act or omission.

    FAQs

    What was the key issue in this case? The key issue was whether the petitioners’ counterclaim, based on quasi-delict, was correctly denied by the lower courts due to their failure to reserve the right to file a separate civil action in a related criminal case.
    What is a quasi-delict? A quasi-delict is an act or omission that causes damage to another due to fault or negligence, where there is no pre-existing contractual relationship between the parties, as defined in Article 2176 of the Civil Code.
    What does it mean to “reserve” a civil action in a criminal case? Reserving a civil action means explicitly stating that you intend to pursue a separate civil case to recover damages arising from the same act that is the subject of the criminal case, preserving your right to do so later.
    Why did the RTC and CA deny the counterclaim? The RTC and CA denied the counterclaim because the petitioners did not reserve the right to file a separate civil action in the criminal case against the respondent’s driver, leading the courts to believe that allowing the counterclaim would result in double recovery.
    How did the Supreme Court rule on the reservation requirement? The Supreme Court ruled that the reservation requirement does not apply to independent civil actions under Articles 32, 33, 34, and 2176 of the Civil Code, allowing them to be filed and prosecuted separately without prior reservation.
    What is the significance of Article 2177 of the Civil Code? Article 2177 prohibits the recovery of damages twice for the same act or omission, ensuring that an injured party is compensated but not unjustly enriched by receiving multiple awards for the same harm.
    What does the term ‘double recovery’ mean in this context? “Double recovery” means receiving compensation more than once for the same loss or injury. The law prevents plaintiffs from being unjustly enriched by recovering multiple times for a single harm.
    What was the final outcome of the case? The Supreme Court reversed the CA’s decision and remanded the case to the RTC for further proceedings to allow the petitioners to present evidence on their counterclaim, subject to the prohibition against double recovery of damages.
    What is civil liability ex delicto? Civil liability ex delicto arises from the commission of a crime and is governed by Article 100 of the Revised Penal Code, requiring every person criminally liable for a felony to also be civilly liable.

    In conclusion, this case underscores the importance of understanding the nuances between criminal and civil liabilities, particularly the rules governing independent civil actions. The Supreme Court’s decision clarifies that the absence of a reservation in a criminal case does not bar a separate civil action based on quasi-delict, ensuring that injured parties can seek compensation for damages caused by negligence or fault, subject to the limitation against double recovery.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Supreme Transportation Liner, Inc. v. Antonio San Andres, G.R. No. 200444, August 15, 2018