Case Digest (G.R. No. 192446)
Facts:
Snow Mountain Dairy Corporation v. GMA Veterans Force, Inc., G.R. No. 192446, November 19, 2014, Supreme Court Third Division, Peralta, J., writing for the Court. On March 11, 2005, Snow Mountain Dairy Corporation (petitioner) and GMA Veterans Force, Inc. (respondent) entered into a one-year security service agreement under which respondent would provide seven security guards working twelve-hour shifts at P16,014.00 per guard per month; the contract stated it could be terminated only for a grave violation and, except for grave violations, required a 30‑day prior notice.On April 13, 2005, petitioner’s president, Teodoro T. Po, notified respondent that petitioner would replace the security personnel effective April 15, 2005, and would settle monies due. Respondent replied the same day insisting the contract was valid for one year, that termination without just cause and without 30‑day notice would obligate petitioner to pay the remainder of the contract (computed as P952,833.00), and offered to negotiate. When no settlement was reached, on June 30, 2005 respondent filed a complaint for damages in the Regional Trial Court (RTC) of Pasig, Branch 268, Civil Case No. 70429, alleging recruitment and deployment expenses and loss of expected income from the unserved portion of the contract; it prayed for actual, moral and exemplary damages, and attorney’s fees.
Petitioner denied liability, argued that President Po could not be sued personally, and maintained that respondent had not proved actual damages. After trial, the RTC rendered judgment on June 19, 2008 ordering petitioner to pay respondent compensatory damages of P952,833.50 (the unserved portion of the contract), plus P100,000.00 attorney’s fees and costs. Petitioner appealed to the Court of Appeals (CA).
On May 31, 2010 the CA, in CA G.R. CV No. 91725, affirmed the RTC’s liability findings but modified the RTC decision by deleting the award of attorney’s fees and dismissing the case against President Po; it otherwise affirmed the award of actual damages of P952,833.50. Petitioner filed the present petition for ...(Pro-only)
Issues:
- Did respondent prove actual or compensatory damages sufficient to justify the RTC’s and CA’s award of P952,833.50?
- If not, may temperate damages be awarded in lieu of actual damages, and if so, in what amount and with ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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