Case Digest (G.R. No. 132319) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Telefast Communications/Philippine Wireless, Inc. vs. Ignacio Castro Sr., et al., decided on February 29, 1988 under the 1973 Philippine Constitution, the plaintiffs–respondents, all residents of the United States, sought damages against Telefast Communications/Philippine Wireless, Inc. (petitioner) for its failure to transmit a telegram. On November 2, 1956, upon the death of Consolacion Bravo-Castro in Lingayen, Pangasinan, her daughter Sofia C. Crouch, then on vacation in the Philippines, paid the required fees and entrusted the petitioner’s Dagupan office with a telegram addressed to her father, Ignacio Castro Sr., at 685 Wanda, Scottsburg, Indiana, U.S.A. The message never arrived. Consolacion was buried attended only by Sofia, and the other family members, all abroad, never learned of the death in time to attend. Upon Sofia’s return to the United States, she discovered the non-receipt of the telegram and, together with her siblings and father, filed Civil Case No. 15356 Case Digest (G.R. No. 132319) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Death of Consolacion Bravo-Castro
- On November 2, 1956, Consolacion Bravo-Castro, wife of Ignacio Castro Sr. and mother of the other plaintiffs, died in Lingayen, Pangasinan.
- Her burial took place on the same day with only her daughter Sofia C. Crouch in attendance.
- Telegram Contract and Non-Transmission
- Also on November 2, 1956, Sofia C. Crouch, then vacationing in the Philippines, engaged Telefast Communications/Philippine Wireless, Inc. (petitioner) to send a death notification telegram to her father, Ignacio Castro Sr., at 685 Wanda, Scottsburg, Indiana, U.S.A., 47170.
- Petitioner accepted payment of the required fees, accepted the message at its Dagupan office, but failed to transmit the telegram and did not notify Sofia of any transmission problem.
- Injury and Suit
- Upon returning to the United States, Sofia learned that the telegram had never been received; neither her father nor her siblings were informed and none attended the funeral.
- Sofia and her siblings then filed Civil Case No. 15356 in the Court of First Instance of Pangasinan, seeking damages for petitioner’s breach of contract and negligence.
- Trial Court and Intermediate Appellate Court Decisions
- The trial court found petitioner liable for breach of its obligation and awarded:
- P31.92 (telegram fee) plus P16,000 compensatory and P20,000 moral damages to Sofia;
- Moral damages ranging from P10,000 to P20,000 for each of the other plaintiffs;
- Exemplary damages of P1,000 each; P5,000 attorney’s fees; costs.
- On appeal (AC-G.R. No. CV-70245), the Intermediate Appellate Court:
- Affirmed liability;
- Eliminated Sofia’s P16,000 compensatory award;
- Eliminated P1,000 exemplary damages per plaintiff;
- Reduced certain moral damages from P20,000 to P10,000.
Issues:
- Whether petitioner’s negligent non-transmission of the telegram constitutes breach of contract and gives rise to damages beyond the paid fee.
- Whether moral damages are recoverable in the absence of fraud, malice or gross recklessness.
- Whether exemplary damages and the expenses of Sofia’s travel to testify are warranted and recoverable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)