Case Digest (G.R. No. 175822)
Facts:
California Clothing, Inc. and Michelle S. Ybanez, Petitioners, vs. Shirley G. Quinones, Respondent, G.R. No. 175822, October 23, 2013, the Supreme Court Third Division, Peralta, J., writing for the Court. Shirley G. Quinones (respondent), a Cebu Pacific reservation ticketing agent, bought a pair of black jeans at the Guess USA Boutique in Robinsons Department Store, Cebu City, on July 25, 2001. She left the store in possession of the jeans and an official receipt she claimed to have received upon payment. While walking toward Mercury Drug via the mall skywalk, Guess employees intercepted her and insisted she had not paid for the jeans; respondent produced the receipt and suggested they talk at the Cebu Pacific office in the mall basement.At the Cebu Pacific office the parties argued; respondent alleged public humiliation and that Guess employees searched her wallet and demanded payment. The Guess employees later prepared a letter addressed to the Director of Cebu Pacific recounting the incident; Cebu Pacific allegedly refused to receive that letter because the matter did not concern the office. A separate letter was allegedly sent to Cebu Pacific’s Robinsons office and the Robinsons Human Resources Department purportedly investigated with a view to canceling respondent’s store credit card; respondent claimed she was not furnished a copy of the letter.
Respondent filed a Complaint for Damages before the Regional Trial Court (RTC), Branch 58, Cebu City (Civil Case No. CEB-26984), naming as defendants California Clothing, Inc., Excelsis Villagonzalo, Imelda Hawayon and Michelle Ybanez; she sought moral, nominal, and exemplary damages, and attorneys’ fees. The defendants admitted issuance of the receipt but explained it was issued due to a miscommunication between the invoicer and cashier; upon discovering the mistake they sought respondent to clarify and later went to the agreed meeting place at the Cebu Pacific office. Defendants counterclaimed for moral and exemplary damages and attorneys’ fees.
On June 20, 2003, the RTC dismissed both the complaint and the counterclaim, finding the Guess employees acted in good faith and exercised a right to verify payment and that respondent herself selected the venue of the confrontation. On appeal, the Court of Appeals (CA) in CA‑G.R. CV No. 80309 reversed and set aside the RTC decision in an August 3, 2006 decision, finding that while the in-person confrontation was in good faith, the demand letter to respondent’s employer was a malicious act that amounted to abuse of rights; the CA ordered petitioners California Clothing, Inc. and Michelle Ybanez to pay jointly and solidarily P50,000.00 moral damages and P20,000.00 attorneys’ fees, and exonerated the other employees Hawayon and Villagonzalo for good faith. Ybanez’s motion for reconsideration before the CA was denied on November 14, 2006.
...(Pro-only)Issues:
- Did petitioners abuse their right in sending the demand letter to respondent’s employer so as to constitute actionable bad faith under the abuse of rights doctrine?
- Were the awards of moral damages and attorneys’ fees proper under th...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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