FACTS:

Judith Darines and her daughter Joyce Darines (petitioners) filed a civil action for damages against Eduardo Quiñones and Rolando Quitan (respondents) after a bus-truck collision. The petitioners claimed that they were paying passengers on an Amianan Bus Line when Quitan, the bus driver, crashed into a parked truck. As a result, both petitioners sustained injuries and two passengers died. According to the petitioners, the respondents breached their contract of carriage and were negligent in their driving, leading to the collision. Consequently, the petitioners sought various types of damages, including actual, moral, exemplary, and temperate damages, as well as the costs of the lawsuit.

The respondents, on the other hand, argued that Quitan had been driving carefully and that the negligence of the truck driver was the primary cause of the incident. During the trial proceedings, the petitioners presented evidence regarding their medical expenses and related costs, while the respondents produced evidence regarding the medical and hospitalization expenses they had paid for on behalf of the petitioners.

In the initial ruling, the Regional Trial Court (RTC) sided with the petitioners, granting them moral damages, exemplary damages, attorney's fees, and costs of the lawsuit. Dissatisfied with the decision, the respondents appealed to the Court of Appeals (CA), which reversed the RTC's ruling. The CA specifically deleted the award of damages and attorney's fees, stating that the petitioners failed to substantiate any fraudulent or bad faith actions on the part of the respondents.

The petitioners then submitted a petition for review on certiorari before the Supreme Court, asserting their entitlement to moral and exemplary damages, as well as attorney's fees under the relevant provisions of the Civil Code. Among the issues raised by the petitioners were whether the damages and attorney's fees awarded by the RTC had become final and executory as the respondents did not challenge them in their appeal, and whether the petitioners were indeed entitled to damages and attorney's fees under the applicable provisions of the Civil Code.

ISSUES:

1. Whether or not the case of petitioners falls under Articles 20, 1157, 1759, 2176, 2180, and 2219 of the Civil Code thereby entitling them to moral and exemplary damages and attorney's fees.

2. Whether or not the award of damages and attorney's fees by the trial court became final and executory since the respondents did not question the same in their appeal but merely questioned the amounts of the award for being exorbitant.

RULING:

1. The Court of Appeals reversed and set aside the decision of the Regional Trial Court, deleting the award of moral damages, exemplary damages, and attorney's fees.

PRINCIPLES:

• There must be proof of fraud or bad faith on the part of the defendant before moral damages can be awarded.

• Exemplary damages cannot be awarded if no moral damages are granted.

• The grant of attorney's fees is justified when the party is compelled to litigate or incur expenses to protect its interest in court.