FACTS:

The case involves a petitioner named Ong Chiu Kwan who was charged with unjust vexation for cutting the electric wires, water pipes, and telephone lines of a business establishment owned by Mildred Ong. Ong Chiu Kwan ordered someone to relocate the lines because they posed a disturbance, but he failed to present a permit allowing him to do so. After a trial, the Municipal Trial Court found Ong Chiu Kwan guilty of unjust vexation and sentenced him to imprisonment for twenty days. The court also ordered him to pay moral damages, exemplary damages, and attorney's fees. Ong Chiu Kwan appealed to the Regional Trial Court, which affirmed the decision of the lower court without providing any reasons. The Court of Appeals dismissed the appeal and agreed with the lower court's finding of guilt. Ong Chiu Kwan then filed a petition for review with the Supreme Court. The Court noted that the decision of the Regional Trial Court was a nullity because it did not comply with constitutional and procedural requirements. However, the Court decided to review the evidence and ruled that Ong Chiu Kwan was indeed liable for unjust vexation. The Court, however, deleted the award of moral damages, exemplary damages, and attorney's fees. The decisions of the lower courts were reversed, and Ong Chiu Kwan was sentenced to pay a fine of P200.00 plus costs.

ISSUES:

1. Did the accused commit unjust vexation by cutting the electric wires, water pipes, and telephone lines of the complainant's business establishment without the necessary permit or authorization?

RULING:

1. Yes, the accused committed unjust vexation by cutting the electric wires, water pipes, and telephone lines of the complainant's business establishment without the necessary permit or authorization. The Supreme Court found that the act of the accused in ordering the cutting of the said lines without proper authorization and timing the interruption during peak hours unjustly annoyed or vexed the complainant. Therefore, the accused is liable for unjust vexation.

PRINCIPLES:

• The Constitution requires that a court decision should clearly and distinctly express the facts and the law on which it is based.

• A memorandum decision, while permitted under certain conditions, should not merely refer to the findings of fact and conclusions of law of the lower court. The court must make its own full findings of fact and conclusions of law.

• The act of cutting electric wires, water pipes, and telephone lines without the necessary permit or authorization can be considered unjust vexation.

• Moral damages may be recovered if they were the proximate result of the defendant's wrongful act or omission.

• An award of exemplary damages is justified if the crime was committed with one or more aggravating circumstances.