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CALIFORNIA CLOTHING v. SHIRLEY G. QUIÑONES

FACTS:

Respondent Shirley G. Quiñones, a Reservation Ticketing Agent of Cebu Pacific Air, went inside the Guess USA Boutique in Robinson's Department Store in Cebu City. She fitted four items and decided to purchase the black jeans worth P2,098.00. Respondent allegedly paid for the jeans and showed the receipt to a Guess employee. However, the employee informed her that she failed to pay for the jeans and an argument ensued. They agreed to meet at the Cebu Pacific Office to discuss the issue. When they arrived, the Guess employees allegedly subjected respondent to humiliation and demanded payment for the jeans. They also allegedly sent a letter to Cebu Pacific Air and Robinson's, accusing respondent of trying to evade payment. As a result of this incident, respondent claimed to have suffered physical anxiety, mental anguish, and besmirched reputation. She filed a complaint for damages against petitioners California Clothing, Inc., Excelsis Villagonzalo, Imelda Hawayon, and Michelle Ybañez. The trial court dismissed the complaint, but the Court of Appeals reversed the decision and ordered petitioners to pay respondent moral damages and attorney's fees.

ISSUES:

  1. Whether the letter sent by the petitioners to respondent's employer subjected respondent to ridicule, humiliation, and similar injury.

  2. Whether the award of moral damages and attorney's fees by the Court of Appeals was proper.

  3. Whether or not the petitioners' accusations against the respondent were unjustified and malicious.

  4. Whether or not the petitioners abused their rights in sending a demand letter to the respondent's employer.

RULING:

  1. The Court held that the issues raised by the petitioners are without merit.

  2. The Court ruled that the accusations made by the petitioners against the respondent were unjustified and malicious. There was no evidence to support the claim that the respondent did not pay for the item she purchased. The petitioners failed to prove that the respondent intentionally took the item without paying for it. The accusations made by the petitioners were detrimental to the reputation of the respondent and were made without substantial evidence.

  3. The Court held that the petitioners abused their rights in sending a demand letter to the respondent's employer. The purpose of the demand letter was not only to collect the disputed amount but also to tarnish the reputation of the respondent in the eyes of her employer. This act is contrary to honesty and good faith. The exercise of a right must be in accordance with its purpose and must not be excessive or unduly harsh. The petitioners, in this case, clearly abused their rights.

PRINCIPLES:

  • Abuse of rights principle under Article 19 of the Civil Code. A person must, in the exercise of legal right or duty, act in good faith. He would be liable if he instead acted in bad faith, with the intent to prejudice another. Good faith refers to the intention to abstain from taking an unconscionable and unscrupulous advantage of another.

  • The elements of abuse of rights are: (1) there is a legal right or duty; (2) which is exercised in bad faith; (3) for the sole intent of prejudicing or injuring another.

  • Abuse of rights - A person should not use his right unjustly or contrary to honesty and good faith. The exercise of a right must be in accordance with its purpose and must not be excessive or unduly harsh.

  • Articles 20 and 21 of the Civil Code - These articles provide that a person who causes damage to another contrary to law or willfully causes loss or injury to another shall compensate the latter for the damage.