Title
California Clothing, Inc. vs. Quinones
Case
G.R. No. 175822
Decision Date
Oct 23, 2013
A Cebu Pacific employee, accused of shoplifting by Guess employees, endured public humiliation and mental anguish. The Supreme Court ruled in her favor, awarding damages for abuse of rights and bad faith actions.

Case Digest (G.R. No. 175822)
Expanded Legal Reasoning Model

Facts:

  • Purchase and Payment Incident
    • Respondent Shirley G. Quiaones, a Cebu Pacific reservation ticketing agent, entered Guess USA Boutique at Robinsons Department Store, Cebu City, on July 25, 2001, tried on four items and decided to purchase a pair of black jeans priced at ₱2,098.00.
    • She presented payment to the cashier and received an official receipt; shortly thereafter, Guess employees intercepted her on the skywalk, insisting she had not paid despite her production of the receipt.
  • Confrontation and Communications
    • Respondent proposed discussing the matter at the Cebu Pacific office in the mall basement; there, Guess employees allegedly humiliated her before clients, demanded payment, and searched her wallet.
    • Guess personnel sent a narrative demand letter to the Cebu Pacific director (who refused to accept it) and another to Robinsons’ Human Resources Department, prompting an inquiry into canceling respondent’s store credit card; respondent averred she was not furnished a copy of the letter.
  • Procedural History
    • Respondent filed a complaint for moral, nominal, and exemplary damages, plus attorney’s fees and litigation expenses, against California Clothing, Inc., Michelle S. Ybañez, and others before the Regional Trial Court (RTC), Civil Case No. CEB-26984.
    • Petitioners admitted the receipt was issued due to employee miscommunication but maintained they believed in good faith that no payment was made; they filed a counterclaim for moral and exemplary damages and attorney’s fees.
    • On June 20, 2003, the RTC dismissed both the complaint and counterclaim, finding no bad faith or malice on the part of Guess employees.
    • On August 3, 2006, the Court of Appeals (CA) reversed and set aside the RTC decision, ordering Ybañez and California Clothing, Inc. to pay respondent jointly and solidarily ₱50,000.00 moral damages and ₱20,000.00 attorney’s fees, holding that sending the employer demand letter was done in bad faith; a November 14, 2006 CA resolution denied reconsideration.
    • Petitioners filed a petition for review on certiorari under Rule 45 before the Supreme Court.

Issues:

  • Whether the Court of Appeals erred in finding that the demand letter sent to the Cebu Pacific office was made in bad faith to subject respondent to ridicule, humiliation, or similar injury.
  • Whether the Court of Appeals erred in awarding moral damages and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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