Case Summary (G.R. No. 175822)
Trial Court’s Good Faith Finding
Respondent sued for moral, nominal, and exemplary damages, plus attorney’s fees; petitioners filed a counterclaim. The RTC dismissed both actions, holding that the employees honestly believed payment had not been made and therefore lawfully exercised their right to demand it. The court found no malice in choosing the Cebu Pacific office for discussion and viewed the request for assistance as non‐prejudicial.
Appellate Court’s Abuse of Rights Ruling
The Court of Appeals reversed, agreeing that the face‐to‐face demand had been made in good faith but concluding that sending a detailed demand letter to respondent’s employer demonstrated bad faith and malice. Given respondent’s possession of the paid item and official receipt, the CA ruled that petitioners abused their right by involving an uninvolved third party to shame her into payment. California Clothing and Ybañez were ordered to pay ₱50,000 moral damages and ₱20,000 attorney’s fees; the two other employees were exonerated for their proven good faith.
Issue on Supreme Court Review
Petitioners contended that the CA erred in finding the letter abusive and in awarding damages. The Supreme Court was asked to determine whether involving respondent’s employer constituted an abuse of right and whether the damage awards were proper.
Principles on Abuse of Rights and Moral Damages
Article 19 of the Civil Code requires the exercise of rights and performance of duties in good faith; abuse for the sole intent of injuring another is actionable. Articles 20 and 21 impose liability for willful or negligent acts contrary to law, morals, or public policy. Moral damages compensate mental anguish, besmirched reputation, and social humiliation caused by wrongful acts. Although petitioners had the right to verify
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Procedural Posture
- Petition for review on certiorari under Rule 45 of the Rules of Court.
- Assailed the Court of Appeals Decision dated August 3, 2006 and Resolution dated November 14, 2006 in CA-G.R. CV No. 80309.
- The CA decision reversed and set aside the June 20, 2003 RTC Decision dismissing both complaint and counterclaim.
- The CA resolution denied petitioner Ybaáez’s motion for reconsideration.
Facts of the Case
- July 25, 2001: Respondent Shirley G. Quiaones entered the Guess USA Boutique at Robinsons Department Store, Cebu City.
- She tried on four items and decided to buy black jeans priced at ₱2,098.00, for which she received an official receipt.
- While walking toward Mercury Drug Store, a Guess employee accused her of non-payment; she produced the receipt and proposed to discuss the matter at the Cebu Pacific Air office.
- At the Cebu Pacific Office, Guess employees publicly demanded payment, searched her wallet, and engaged in loud argument, causing her humiliation in front of clients.
- Guess employees prepared a letter to the Director of Cebu Pacific Air narrating the incident; the letter was refused. A second letter addressed to the Robinsons Cebu Pacific Office was likewise declined.
- The Human Resources Department of Robinsons allegedly received the letter and investigated her credit privileges without furnishing her a copy.
- Respondent claimed physical anxiety, sleepless nights, mental anguish, fright, serious apprehension, besmirched reputation, moral shock, and social humiliation.
Trial Court Ruling (RTC)
- Dismissed both the complaint and counterclaim.
- Held that Guess employees acted in good faith under honest belief of non-payment and merely exercised a right to verify.
- Found no bad faith or malicious intent in confronting re