Case Digest (G.R. No. 235737) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sps. Melchor and Yolanda Dorao v. Sps. BBB and CCC (G.R. No. 235737, April 26, 2023), petitioners Melchor and Yolanda Dorao are the parents of Paul, then the boyfriend of minor AAA, daughter of respondents BBB and CCC. Both AAA and Paul studied at a special science high school in La Union and, without their parents’ knowledge, formed a “mutual understanding” friendship in July 2004. Beginning in August 2004, the Dorao Spouses repeatedly appeared at the school to harass and intimidate AAA, publicly calling her “malandi”, “makati ang laman”, and accusing her of loose morals in front of classmates, parents, and teachers. They also spread false rumors to other parents and even contacted CCC by phone and text, further tarnishing AAA’s reputation. As a result, AAA suffered depression, lost her academic distinction, attempted suicide, dropped out of her school, and transferred universities. BBB and CCC filed Civil Case No. 740 before the Regional Trial Court (RTC) of La Union seekin Case Digest (G.R. No. 235737) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationships
- Petitioners Spouses Melchor and Yolanda Dorao are parents of Paul, then‐boyfriend of minor AAA.
- Respondents Spouses BBB and CCC are AAA’s parents and filed suit on behalf of their daughter.
- Underlying Incidents and Harassment
- In July 2004, AAA and Paul, both minors and students at a La Union school, began a “mutual understanding.”
- From August 2004, Yolanda Dorao frequently visited the school, publicly insulting AAA with terms such as “malandi” and “makati ang laman,” spreading rumors among parents and students, and admonishing CCC via calls and texts that AAA had “loose morals.”
- Melchor Dorao likewise publicly accused AAA of seducing Paul, humiliating her at a parents’ meeting on November 30 2004. These acts continued despite requests by BBB to desist.
- AAA suffered depression, loss of honor‐student status and leadership posts, attempted suicide by overdose, withdrew from her original school, and transferred twice, alleging harassment, loss of privacy, and injury to reputation.
- Procedural History
- On March 2005, Spouses BBB and CCC filed a complaint for moral and exemplary damages (P100,000 and P50,000 respectively) under Articles 21 and 26 of the Civil Code.
- The Regional Trial Court (RTC) on October 28 2015 found the Dorao Spouses liable, awarding AAA P30,000 moral damages, P20,000 exemplary damages, and P30,000 attorney’s fees.
- On July 11 2017, the Court of Appeals (CA) affirmed the RTC decision; its October 26 2017 resolution denied the Dorao Spouses’ motion for reconsideration.
- The Dorao Spouses filed a Petition for Review under Rule 45 before the Supreme Court, contesting factual findings, witness credibility, and applicability of parental duty.
Issues:
- Procedural Compliance
- Whether the Petition for Review should be dismissed for failure to comply with Rule 45 and related Supreme Court e-filing circulars (absence of verified declaration, proof of service, and supporting record excerpts).
- Substantive Liability
- Whether petitioners, not being AAA’s parents or legal guardians, had any parental authority over her to justify their conduct.
- Whether their public insults, harassment, and rumor‐mongering violated AAA’s and her parents’ rights to dignity, personality, privacy, and peace of mind under Articles 21 and 26 of the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)