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Ylarde vs Aquino

GR No. L33722, July 29, 1988



FACTS: Aquino, a teacher at Gabaldon Primary School in Pangasinan, gathered 18 of his male
students to help clear several concrete blocks which were remnants of the old school shop. He
ordered them to dig beside a one ton concrete block in making a hole where it can be
buried. The following day he called 4 of the 18 students including the Novelito Ylarde to
complete the excavation. He left the children to get some rope and told them not to touch the
stone. After he left, the children playfully jumped into the pit when suddenly the concrete
block slide down. Unfortunately, Ylarde was pinned to the wall causing serious physical injuries
which eventually led to his death.

ISSUE: WON both Soriano, as principal, and Aquino, as teacher, can be held liable for damages.

HELD: Teachers in general shall be liable for the acts of their students except where the school
is technical in nature, in which case it is the head thereof who shall be answerable. Hence,
Soriano as principal cannot be held liable for the reason that the school he heads is an
academic school and he did not give any instruction regarding the digging. On the other hand,
Aquino acted with fault and gross negligence where instead of availing himself of adult manual
laborers he instead utilized his students. Furthermore, the warning given is not sufficient to
cast away all serious danger that the concrete block adjacent to the excavation would present
to the children.

VENTANILLA v CENTENO
G.R. No. L-14333, January 28,1961

Facts of the Case:
In an action for recovery and damages, Oscar Ventanilla retained the services of Atty.
Gregorio Centeno. The decision unfavorable to Ventanilla was received by Centeno on 21 July
1995 and thereafter Centeno filed a Notice of Appeal. Ventanilla, however, instead of executing
an appeal bond, and because use of his reluctance to pay the premium on the appeal bond,
decided to file a cash appeal bond of P60.00. He went to the office of Centeno, but was
informed by the clerk that Centeno was in Laguna campaigning for his candidacy as member of
the Provincial Board. Ventanilla then issued the check for P60.00 as appeal bond with
instruction to give the same to Centeno upon his arrival. When Centeno went to file the appeal
bond, it was not accepted because the period of appeal had already expired.

Issue:
WON Ventanilla was entitiled to recover damages.

Ruling: Ventanilla is not entitled to actual damages because in filing an appeal, there is no
assurance that it would be granted and thus, highly speculative. However, he was awarded
nominal damages considering the circumstances and the degree of negligence committed by
his counsel.

PEOPLE v. PRINCIPE
[G.R. No. 135862. May 2, 2002]
EN BANC
Facts:
Accused Rafael Principe was convicted of homicide with rape. The trial court sentenced him to
suffer the penalty of death and to indemnify the heirs of the deceased the sum of
p
50,000.00,
and the sum of
p
21,307.00 for funeral expenses.
Issues:
Whether or not the award for actual damages is proper.

Held: NO. The father of the victim failed to present receipts to prove the expenses incurred
during the funeral. Instead, the court awarded temperate damages since the fact remains
that the heirs of the victim incurred funeral expenses. In addition, the heirs are entitled to
moral damages in the amount of
p
50,000.00 for the physical suffering, mental anguish, serious
anxiety, and moral shock caused by the manner by which Arlene was raped and killed.




Tan et al vs. OMC

Facts of the Case:
Arambala was driving a truck

with a trailer owned by OMC when he noticed that the
truck had suddenly lost its brakes. He told his companion to jump out. Soon thereafter, he also
jumped out and abandoned the truck. Driverless, the truck rammed into the house and
tailoring shop owned by petitioner Leticia Tan and her husband Celedonio Tan, instantly killing
Celedonio who was standing at the doorway of the house at the time.

ISSUE: Is the award of damages proper?

HELD:
The petitioners are entitled to Temperate Damages in lieu of actual damages, as the
petitioners did not submit any receipt to prove the monetary value of the damage caused. As a
rule, documentary evidence should be presented to claim for loss of earning capacity.

ALBETZ INVESTMENTS, INC vs.CA
G.R. No. L-32570 February 28, 1977

FACTS
The Calma spouses were the lessees of that lot owned by Albetz Investments, Inc.
Petitioner needing the premises in order to construct a new building, demanded delivery of the
lot to it and upon refusal of the Calma Spouses, it brought an action of unlawful detainer
against Vicenta Calma. Later, petitioner then filed a motion for demolition awhich was granted
giving the defendant 30 days from the receipt thereof to vacate and remove her house on the
premises. Vicenta Calma having failed to remove the house within the 30 day period and upon
motion of Albetz investments, Inc., the Court issued an order authorizing and ordering the
Sheriff to destroy, demolish or remove the house which had been constructed by the
defendants. The Sheriff, at the instance of defendant Albetz Investments, Inc., demolished the
house of the spouses Calma without any new writ or order for demolition.

ISSUE
WON the spouses are entitled to payment of damages

HELD
Yes. Certainly, the demolition complained of in the case at bar was not carried out in a
manner consistent with justice and good faith. At the instance of petitioner, it was done in a
swift, unconscionable manner, giving the occupants of the house no time at all to remove their
belongings therefrom.



Reyes et al v. Hon. Arca
GR L-21447 November 29, 1965
Facts of the Case:
Spouses Basa leased to Eusebio Millar 3 parcels of registered land with improvements.
Later, the property was sold to Reyes et al; the new owners respected the lease in favor of
Millar. Millar filed an action to declare the sale null and void, to be allowed to exercise the
option to purchase, and to recover P10k as actual and moral damages and P3k as attorneys
fees. The defendants argued that Millar already waived his option to buy. At first, Millar
deposited with the court monthly rentals but subsequently withdrew accumulated amount. The
buyers sought to compel Millar to deposit his monthly rentals from January 1959 to April 1963.

ISSUE: Can the new owners compel Millar to pay rentals?

Ruling: YES. Millar did not cease to be the lessee, the same was respected by the buyers, and
he continued to occupy the properties leased to him. As lessee, he is obliged to pay the price
according to the terms stipulated. There is, in effect, unjust enrichment without payment for
enjoyment of the property belonging to another. Nonpayment of rentals by Millar constitutes
unjust enrichment.


RCPI v. CA
G.R. No. L-44748, August 29, 1986

FACTS:
A complaint was filed against the defendant RCPI based on a telegram sent through its
office to the offended party, Loreto Dionela. He alleges that the defamatory words on the
telegram sent to him not only wounded his feelings but also caused him undue embarrassment
and affected adversely his business as well because other people have come to know of said
defamatory words. RCPI as a defense, alleges that the additional words in Tagalog was a private
joke between the sending and receiving operators and that they were not addressed to or
intended for plaintiff and therefore did not form part of the telegram and that the Tagalog
words are not defamatory. Nobody other than the operator manned the teletype machine
which automatically receives telegrams being transmitted.

ISSUE: WON Dionela is entitled to damges

DECISION:
YES. The cause of action of the private respondent is based on Articles 19 and 20 of the
New Civil Code. As well as on respondent's breach of contract thru the negligence of its own
employees. There is no question that in the case at bar, libelous matters were included in the
message transmitted, without the consent or knowledge of the sender. There is a clear case of
breach of contract by the petitioner in adding extraneous and libelous matters in the message
sent to the private respondent. As a corporation, the petitioner can act only through its
employees. Hence the acts of its employees in receiving and transmitting messages are the acts
of the petitioner.

Jardine Davies Inc. vs. CA (June 19, 2000)


Facts: Purefoods conducted a bidding for the supply and installation of 2 generators in its food
processing plant and among the bidders was FEMSCO. Purefoods confirmed in a letter the
award of the contract to FEMSCO. Immediately FEMSCO submitted the necessary. However, in
another letter, Purefoods unilaterally cancelled the award. FEMSCO protested the cancellation
but before the matter could be resolve, Purefoods awarded the project with Jardine Nell, a
division of Jardine Davies.

Issue: Whether or not moral damages may be granted to a corporation?

Held: As a general rule, No. However, FEMSCO has sufficiently shown that its reputation was
tarnished after it immediately ordered equipment from its suppliers on account of the urgency
of the project, only to be canceled later.



PEOPLE v. MANERO
G.R. Nos. 86883-85 January 29, 1993

FACTS
Fr. Tulio Favali

was senselessly killed for no apparent reason by a group commanded by
Norberto Manero Jr. The accused was found guilty for murder, with aggravating circumstance of
superior strength and treachery and the penalty was reclusion perpetua and was ordered to pay the
PIME Brothers, the congregation to which Father TulioFavali belonged, civil indemnity including moral
damages.

ISSUE
WON it is proper to award moral damages to PIME?

RULING
NO. A juridical person is not entitled to moral damages because, not being a natural person, it cannot
experience physical suffering or such sentiments as wounded feelings, serious anxiety, mental anguish
or moral shock. It is only when a juridical person has a good reputation that is debased, resulting in
social humiliation, that moral damages may be awarded.

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