Title
Radio Communications of the Philippines, Inc. vs. Rodriguez
Case
G.R. No. 83768
Decision Date
Feb 28, 1990
RCPI failed to deliver telegrams, causing Rodriguez humiliation and inconvenience. SC upheld actual damages but reduced moral damages, deleted exemplary damages and attorney's fees.
A

Case Digest (G.R. No. 83768)

Facts:

  • Background and Procedural History
    • On September 8, 1978, Rufus B. Rodriguez, President of the World Association of Law Students (WALS), sent two cablegrams via Radio Communications of the Philippines, Inc. (RCPI), relayed to Globe Mackay and Radio Corporation for overseas transmission—one to Mohamed Elsir Taha in Khartoum, Sudan, and another to Diane Merger in Athens, Georgia, USA.
    • The cablegrams were not delivered: Taha did not receive the telegram due to an incomplete address; Merger did not receive hers because she had moved and no forwarding was noted.
    • Rodriguez arrived in Khartoum at 9:30 PM on September 18, 1978; nobody met him, forcing him to sleep at the airport. The scheduled WALS conference was cancelled; subsequent meetings were held elsewhere.
    • On December 8, 1978, Rodriguez filed a complaint for P45,147 actual damages, P200,000 moral damages, and P50,000 exemplary damages against RCPI and Globe Mackay.
    • On March 17, 1980, the Court of First Instance of Rizal awarded P213,148 in total damages (P100,000 moral; P50,000 exemplary; P43,148 actual; P20,000 attorney’s fees). The Court of Appeals affirmed; this Court’s earlier decision (G.R. No. 59311, 134 SCRA 395 [1985]) authorized execution pending appeal only for actual damages.
    • In the present petition (G.R. No. 83768), only RCPI challenged liability and the awards of damages and attorney’s fees.
  • Contractual and Operational Arrangement
    • RCPI, lacking direct foreign facilities, contracted Globe Mackay to transmit its international messages under an inter-connecting agreement; both testified that each transmits the other’s messages domestically/internationally.
    • By accepting Rodriguez’s instructions and fees, RCPI undertook a contractual obligation under Articles 1170 and 2176 of the Civil Code to deliver the messages or notify non-delivery.

Issues:

  • Whether RCPI is responsible for the non-delivery of the two telegrams despite relaying them to Globe Mackay.
  • Whether, under the attendant facts and circumstances, RCPI is liable for:
    • Moral damages of P100,000.00;
    • Exemplary damages of P50,000.00;
    • Actual damages of P43,148.00;
    • Attorney’s fees of P20,000.00.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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