Case Digest (G.R. No. 232798)
Facts:
Advan Motor, Inc. v. Lila R. Saavedra, G.R. No. 232798, December 07, 2022, the Supreme Court Second Division, Leonen, SAJ., writing for the Court. Petitioner Advan Motor, Inc. is a car dealer/repair shop; respondent Lila R. Saavedra is the buyer-owner of a Chevrolet Zafira. On March 26, 2002 Saavedra purchased the Zafira for P1,190,000.00. On February 2, 2007 she brought the vehicle to Advan for repair (rough idling and dashboard symbols); the vehicle's insured/estimated value at that time was P700,000.00.Advan issued a repair order and performed some diagnostics; between February and June 2007 Advan requested parts, sought a computer box from Saavedra, and later informed her of additional needed repairs. Saavedra repeatedly sought information and the vehicle's release; on June 16, 2007 she requested return of the Zafira regardless of condition, which Advan denied, claiming the engine had been dismantled and sent out for repair. On July 9, 2007 Saavedra demanded payment of the vehicle's market value and declared she was no longer interested in getting back the Zafira. When that demand was ignored she filed suit (Complaint filed January 11, 2008) for sum of money and damages, alleging breach of the repair contract and deprivation from using the vehicle.
The Regional Trial Court (RTC) of Parañaque City, Branch 195, after trial, found Advan in breach for failing to carry out the repair order and ruled that return was no longer feasible; it awarded P700,000.00 (vehicle value), monthly installments of a replacement Toyota Vios from January 11, 2008 until paid, P20,000.00 moral damages, P20,000.00 exemplary damages, attorney’s fees of P100,000.00 plus P5,000.00 appearance fee per hearing, and costs. Advan appealed to the Court of Appeals (CA).
The Court of Appeals in CA-G.R. CV No. 104257 (Decision dated January 31, 2017) found Advan liable for breach but modified reliefs: it ordered Advan to return the Zafira in good order and condition and awarded P200,000.00 temperate damages, P200,000.00 moral damages, P200,000.00 exemplary damages, attorney’s fees of P100,000.00 plus P5,000.00 per hearing, and costs. The CA denied Advan’s Motion for Reconsideration. Advan filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
In its petition Advan contended the CA awarded reliefs not prayed for (ordering return of the vehicle and increasing damages), that Saavedra had abandoned the vehicle and never sought its return in prior proceedings, and that increases in damages were i...(Subscriber-Only)
Issues:
- Did the Court of Appeals validly grant relief not prayed for by the parties when it ordered the return of the Zafira in good working condition?
- Were the damages awarded by the Court of Appeals to respondent Lila R. Saavedra proper?
- Was it proper for the Court of Appeals to increase the amounts of moral and exemplary damages despite respondent’s failu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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