View full case

JOYCE V. ARDIENTE v. SPS. JAVIER

FACTS:

Petitioner Joyce V. Ardiente and her husband Dr. Roberto S. Ardiente sold their housing unit to respondent Ma. Theresa Pastorfide through a Memorandum of Agreement. The agreement transferred all rights and interests in the property to Pastorfide in exchange for P70,000. It also stated that Pastorfide would assume the payment of a mortgage loan and be responsible for the water and power bills of the property. Pastorfide used the water connection without issue until it was unexpectedly cut off on March 12, 1999. Pastorfide later discovered that she had been delinquent in paying the bills and that Ardiente was responsible for initiating the disconnection. Pastorfide paid the delinquent bills and filed a complaint for damages against Ardiente, the Cagayan de Oro Water District (COWD), and its manager Gaspar Gonzalez. The Regional Trial Court (RTC) held Ardiente, COWD, and Gonzalez liable and ordered them to pay damages. The Court of Appeals (CA) affirmed the RTC decision but reduced the damages awarded. Ardiente, COWD, and Gonzalez filed motions for reconsideration, which were denied by the CA. The Supreme Court denied the separate petition for review filed by COWD and Gonzalez for technical reasons. Ardiente now seeks to reverse the CA decision through the present petition.

ISSUES:

  1. Whether the principle of abuse of rights has been violated resulting in damages under Article 20 or other applicable provision of law.

  2. Whether the petitioner, COWD, and Gonzalez are solidarily liable for the damages suffered by the respondent spouses.

  3. Whether the respondent spouses are entitled to moral damages.

  4. Whether the respondent spouses are entitled to exemplary damages.

  5. Whether the respondent spouses are entitled to attorney's fees.

RULING:

  1. The Court held that the principle of abuse of rights has been violated resulting in damages under Article 20 of the Civil Code. The petitioner, COWD, and Gonzalez are solidarily liable for their unjustifiable act of disconnecting the respondent spouses' water supply without prior notice or warning.

  2. The Court affirmed the ruling that the petitioner, COWD, and Gonzalez are solidarily liable for the damages suffered by the respondent spouses.

  3. The Court held that the respondent spouses are entitled to moral damages based on the provisions of Article 2219, in connection with Articles 20 and 21 of the Civil Code.

  4. The Court sustained the award of exemplary damages, although the amount was reduced. Exemplary damages serve as a deterrent against socially deleterious actions, and in this case, the respondent spouses were deprived of their water supply for more than nine months.

  5. The Court awarded attorney's fees based on Article 2208 of the Civil Code, considering that the defendant's act or omission compelled the plaintiffs to litigate and the defendant acted in gross and evident bad faith in refusing to satisfy the plaintiffs' valid claim.

PRINCIPLES:

  • Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith, as provided by Article 19 of the Civil Code.

  • When there is a violation of Article 19, an action for damages under either Article 20 or Article 21 would be proper.

  • The principle of abuse of rights is codified in Article 19 of the Civil Code, which sets standards for the exercise of rights and the performance of duties, such as acting with justice, giving everyone his due, and observing honesty and good faith.

  • Abuse of rights may result in damages under Article 20 of the Civil Code, which provides that every person who willfully or negligently causes damage to another contrary to law shall indemnify the latter.

  • Exemplary damages may be awarded to serve as a deterrent against socially deleterious actions and are not meant to enrich one party or impoverish another.

  • Attorney's fees may be awarded when exemplary damages are awarded, when the defendant's act or omission compelled the plaintiff to litigate, or when the defendant acted in gross and evident bad faith in refusing to satisfy a valid claim.