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IGLECERIO MAHINAY v. ATTY. GABINO A. VELASQUEZ

FACTS:

The case involves a petition for review of a decision affirming with modification an order and resolution of the Regional Trial Court (RTC) in a damages case. The dispute arose from alleged defamatory remarks made by the petitioner against the respondent. The overseer of the respondent testified that the petitioner called the respondent's master, a candidate for Congressman, a land grabber. This led the respondent to file a complaint for damages, asserting that the petitioner's statements tarnished his and his family's reputation and caused him mental anguish. The trial court ruled in favor of the respondent based on the overseer's testimony alone, awarding moral damages of P100,000 and exemplary damages of P50,000. The petitioner appealed to the Court of Appeals, which affirmed the trial court's decision with modification, reducing the award of moral and exemplary damages to P50,000 and P25,000, respectively. The petitioner then brought the case to the Supreme Court, arguing that the appellate court erred in affirming the trial court's order without sufficient factual basis and in awarding damages despite the respondent's failure to testify. The Supreme Court agreed with the petitioner, finding that there was a lack of evidence to support the damages awarded, as the respondent did not testify to his alleged mental and emotional suffering. Therefore, the Supreme Court reversed the decision of the Court of Appeals and dismissed the complaint for damages.

ISSUES:

  1. Whether the court erred in affirming the trial court's order despite the lack of sufficient factual basis.

  2. Whether the court erred in awarding moral and exemplary damages to respondent despite his failure to take the witness stand.

RULING:

  1. Yes. The court held that in order to award moral damages, there must be pleading and proof of moral suffering, mental anguish, fright, and similar experiences. While respondent alleged in his complaint that he suffered mental anguish, serious anxiety, wounded feelings, and moral shock, he failed to prove them during the trial. The court emphasized that mere allegations are not enough; they must be substantiated by clear and convincing proof. As the respondent did not take the witness stand and testify on his purported suffering, there was no factual basis for the trial court to award moral damages.

  2. Yes. The court ruled that respondent is not entitled to exemplary damages. Exemplary damages can only be awarded if the claimant first establishes his clear right to moral damages. Since the respondent failed to testify and prove his moral damages, he cannot be awarded exemplary damages. Furthermore, exemplary damages can only be awarded if the party acted in a wanton, oppressive, or malevolent manner, which was not proven in this case.

PRINCIPLES:

  • In order to be awarded moral damages, there must be pleading and proof of moral suffering, mental anguish, fright, and similar experiences.

  • Mere allegations of moral damages are not enough; they must be substantiated by clear and convincing proof.

  • The claimant of moral damages must testify on his/her social humiliation, wounded feelings, and anxiety to support the claim.

  • Exemplary damages can only be awarded if the claimant has established his clear right to moral damages.

  • Exemplary damages can only be awarded if the party acted in a wanton, oppressive, or malevolent manner.