Filinvest vs. IAC

Kinds of Damages | Supplemental Laws
Filinvest Credit Corp. vs. IAC

G.R. No. L-65935 | September 30, 1988
Syllabus
Damages are not intended to enrich the complainant at the expense of a defendant. They
are awarded only to enable the injured parties to obtain means, diversions or amusements that
will serve to alleviate the moral sufferings the injured parties have undergone by reason of
defendant's culpable action.
The award of moral damages is aimed at a restoration within the limits of the possible, of
the spiritual status quo ante; and therefore it must be proportionate to the suffering inflicted.
Moral damages though not incapable of pecuniary estimations, are in the category of an
award designed to compensate the claimant for actual injury suffered and not to impose a
penalty on the wrongdoer.
Facts
1. On March 21, 1978, Nestor B. Sunga Jr., businessman and owner of the NBS Machineries
Marketing and the NAP-NAP Transit, purchased a passenger minibus Mazda from the Motor
Center, Inc.
2. On the same date, Sunga Jr. executed a promissory note to cover the total amount of
₱62,592.00 payable by ₱2,608.00 monthly for 2 years due (May 1, 1978-1980).
3. On the same date, Sunga Jr. further executed a chattel mortgage favoring the Motor Center,
Inc. and assigning the same to Filinvest Credit Corp.
4. On October 21, 1978, the minibus was seized by 2 Filinvest employees.
5. The seize was ordered by Filinvest Branch Mngr. Gaspar de los Santos, w/o receipt.
6. De los Santos claimed that Sunga Jr. was delinquent in the payments of his vehicle.
7. Sunga Jr. reported the loss to the PC, and after proper verification from Filinvest, the minibus
was recovered from the Crisologo Compound.
8. The minibus was later released by Filinvest Asst. Mngr. Rosario Fronda Crisologo
Compound Caretaker Arturo Balatbat.
9. Such events were recorded under the police blotter of the Integrated National Police of
Dagupan City, assisted by the Dagupan Police and Florence Onia of Filinvest.
10. Onia admitted it was their fault.
11. The minibus was returned to the Sunga Jr. upon proper receipt.
12. After trial, court a quo ordered Filinvest to pay Sunga Jr. ₱30,000.00 for moral damages,
₱600.00 for three-day loss on income, ₱500.00 for actual damages, ₱5,000.00 for litigation
expenses, and ₱10,000.00 for Attorney’s Fees; and pay costs.
13. Dissatisfied, Filinvest appealed to IAC, where IAC affirmed in toto the decision of the court
a quo, however, further increasing payment of moral damages to ₱50,000.00.
Issues
Whether IAC committed a grave abuse of discretion in increasing extravagantly the award of
moral damages and in granting litigation expenses.
Ruling
Yes. IAC committed a grave abuse of discretion.
a. Well settled is the rule in this jurisdiction that whenever an appeal is taken in a civil case,
an appellee who has not himself appealed cannot obtain from the appellate court any
affirmative relief other than the ones granted in the lower court decision.
b. There is no hard and fast rule in the determination of the fair amount of moral damages,
since each case must be governed by its own peculiar circumstances.
c. In the case of moral damages, the amount awarded should not be palpably and
scandalously excessive so as to indicate that it was the result of passion, prejudice or
corruption on the part of the trial court.
d. In the case, Sunga Jr. is entitled to moral damages due to the unwarranted seizure of the
minibus, allegedly because he was delinquent in the payment of its monthly
amortizations, which turned out to be incorrect, that tainted the reputation of Sunga Jr. in
the business community, thus causing him mental anguish, serious anxiety, besmirched
reputation, wounded feelings, moral shock, and social humiliation.
e. However, the award of moral damages even in the sum of ₱30,000.00 is excessive
considering that Sunga Jr. lost the minibus for only 3 days.
f. Damages are not intended to enrich the complainant at the expense of a defendant, but
are awarded only to enable the injured parties to obtain means, diversions or amusements
that will serve to alleviate the moral sufferings the injured parties have undergone by
reason of defendant's culpable action.
g. The award of moral damages is aimed at a restoration within the limits of the possible, of
the spiritual status quo ante; and therefore it must be proportionate to the suffering
inflicted.
h. Moral damages though not incapable of pecuniary estimations, are in the category of
an award designed to compensate the claimant for actual injury suffered and not to
impose a penalty on the wrongdoer.

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Kinds of Damages | Supplemental Laws

Filinvest Credit Corp. vs. IAC

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