Case Digest (G.R. No. 79578)
Facts:
Radio Communications of the Philippines, Inc. v. Hon. Court of Appeals, and Spouses Minerva Timan and Flores Timan, G.R. No. 79578, March 13, 1991, Supreme Court Second Division, Sarmiento, J., writing for the Court.
Petitioners are Radio Communications of the Philippines, Inc. (RCPI); respondents are the Spouses Minerva Timan and Flores Timan and the Court of Appeals as appellee in the challenged judgment. On January 24, 1983 the Timans sent a social telegram of condolence by contracting with RCPI at its Cubao station to transmit a message to Mr. and Mrs. Hilario Midoranda in Trinidad, Calbayog City. The message text was correctly transmitted, but RCPI’s personnel placed the condolence text on a typewritten “Happy Birthday” card and delivered it inside a colorful “Christmasgram” envelope.
Believing the form and envelope inappropriate, humiliating and indicative of callousness, the Timans demanded explanation from RCPI. Unsatisfied with RCPI’s letters of explanation (dated March 9 and April 20, 1983), they filed a complaint for damages before the Regional Trial Court, Quezon City (Civil Case No. Q-38497). At pre-trial the parties stipulated the central issue: whether delivering a condolence message in a birthday card inside a Christmasgram envelope constituted breach of contract and, if so, whether plaintiffs were entitled to damages.
The trial court (Judge Johnico G. Serquina) rendered judgment on February 14, 1985 awarding P30,848.05 as actual and compensatory damages, P10,000 as moral damages, P5,000 as exemplary damages, attorney’s fees of P5,000 and costs against RCPI. The Court of Appeals, in CA-G.R. CV No. 06008 (promulgated August 14, 1987; ponente Magsino, J.), affirmed the trial court in toto. RCPI then filed a petition for review on certiorari with the Supreme Cou...(Subscriber-Only)
Issues:
- Did RCPI’s delivery of the condolence message in a birthday card and Christmas envelope constitute a breach of contract and/or gross negligence by a business affected with public interest?
- Are the respondents entitled to actual and compensatory damages for the embarrassment and illness alleged to have resulted from RCPI’s conduct?
- Are the respondents entitled to moral and exemplary (punitive) damages under the circumstances? ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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