Case Digest (G.R. No. 114841-42)
Facts:
Atlantic Gulf and Pacific Company of Manila, Inc. v. Court of Appeals, Carlito D. Castillo, Heirs of Cristeta Castillo and Cornelio Castillo, G.R. Nos. 114841-42, August 23, 1995, Second Division, Regalado, J., writing for the Court.In 1982 Atlantic Gulf and Pacific Company of Manila, Inc. (petitioner) began building a steel fabrication plant in Bauan, Batangas, undertaking dredging operations in Batangas Bay adjacent to lands owned by private respondents Carlito D. Castillo, Cristeta Castillo (for herself and as guardian of Cornelio Castillo). Two separate suits were filed: Civil Case No. 10276 by Carlito and Civil Case No. 10696 by Cristeta (for Cornelio). On August 19, 1985 the two cases were consolidated because they presented virtually identical issues and common evidence.
Private respondents alleged that petitioner's personnel and heavy equipment trespassed upon and occupied portions of their land, used the areas as depots/parking without consent or rent and that dredging caused sea silt and water to overflow onto their agricultural lands, rendering them infertile and unsuitable for palay production (previously averaging about 75 cavans annually per lot). Petitioner denied trespass and contended the siltation resulted from Typhoon “Ruping” in 1982.
The Regional Trial Court (Makati, Branch 150; decision promulgated September 6, 1990, penned by Assisting Judge Cecilio F. Balagot) found petitioner liable and awarded specified compensatory damages to each plaintiff plus exemplary damages, attorney’s fees and costs. Petitioner appealed to the Court of Appeals. On March 29, 1994 the Court of Appeals affirmed with modifications, substantially increasing the compensatory awards for Cristeta and Cornelio and awarding interest, exemplary damages, attorneys’ fees and costs.
Petitioner then filed a petition for review on certiorari under Rule 45 from the Court of Appeals’ decision, assailing (1) alleged excessive damages under Arts. 20 and 2176, Civil Code, (2) grave abuse of discretion warranting certiorari, and (3) violation of Art. 2177...(Pro-only)
Issues:
- Did the Court of Appeals exceed its jurisdiction by increasing the award of damages in favor of private respondents who did not appeal the trial court’s decision?
- Were the factual findings of liability and the trial court’s awards supported by substantial evidence so as to justify affirmance...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)