Title
Ong Chiu Kwan vs. Court of Appeals
Case
G.R. No. 113006
Decision Date
Nov 23, 2000
Ong Chiu Kwan cut utility lines of "Crazy Feet" without a permit, causing unjust vexation. SC ruled RTC decision void, upheld guilt, imposed fine, and deleted damages.
unjust vexation
cutting utility lines
permit
A

Case Summary (G.R. No. 113006)

Factual Background

On April 24, 1990, at around 10:00 in the morning, Ong Chiu Kwan ordered Wilfredo Infante to “relocate” the telephone, electric, and water lines of “Crazy Feet.” The petitioner justified the action by claiming that the lines were a disturbance. He nevertheless failed to present any permit or authorization from appropriate authorities that would allow him to cut or relocate the electric wires, water pipe, and telephone lines of the complainant’s business establishment. The cutting resulted in the interruption of the complainant’s business operations during peak hours. The prosecution later alleged unjust vexation as the offense for those acts.

Filing of the Information and Municipal Trial Court Ruling

On January 31, 1991, Assistant City Prosecutor Andres M. Bayona filed an information with the Municipal Trial Court, Bacolod City, charging the petitioner with unjust vexation for cutting the electric wires, water pipes, and telephone lines of “Crazy Feet.” After trial, on September 1, 1992, the municipal court found the petitioner guilty beyond reasonable doubt and sentenced him to “imprisonment for twenty days.” The court also ordered the payment of moral damages for the interruption of business operations during peak hours, exemplary damages as a deterrent, and attorney’s fees.

The municipal court expressly framed the conviction as one under Article 287, par. 2, of the Revised Penal Code and disposed of the case by directing payment of P10,000.00 as moral damages, P5,000.00 as exemplary damages, and P5,000.00 as attorney’s fees, plus costs. It is further noted that the municipal court’s wording on imprisonment was not aligned with the terminology of the Revised Penal Code, the Supreme Court later addressing that the proper term is “twenty days of arresto menor.”

Regional Trial Court Appeal and Defective Decision

The petitioner appealed to the Regional Trial Court, Bacolod City. In its December 8, 1992 decision, the Regional Trial Court affirmed “in toto” the municipal court’s decision and added language indicating it had required memoranda and that, after perusal of the record, it found no reason to modify the lower court’s ruling. The Regional Trial Court did not state its own clearly and distinctly articulated findings of fact and conclusions of law.

When scrutinized, the Supreme Court observed that the Regional Trial Court merely quoted the municipal court decision in full and appended two brief paragraphs about the filing of memoranda and the court’s lack of grounds to reverse. It did not undertake the constitutionally mandated task of expressing clearly and distinctly the facts and the law on which its decision was based.

Court of Appeals Review

The petitioner then filed a petition for review with the Court of Appeals on April 22, 1993. On August 16, 1993, the Court of Appeals dismissed the appeal. It agreed with the lower courts’ conclusion that the petitioner was guilty beyond reasonable doubt of unjust vexation. The Supreme Court later noted that the Court of Appeals’ disposition did not correct the Regional Trial Court’s defective decision.

Issues Raised in the Supreme Court

Before the Supreme Court, the controlling matters included whether the lower courts’ rulings complied with the constitutional and procedural requirements for the contents of decisions, and whether the evidence supported the conviction for unjust vexation and the awards of damages. The Supreme Court also addressed the propriety of the damages, particularly moral and exemplary damages and attorney’s fees, in light of the record and the governing standards under the Civil Code.

Constitutional and Procedural Defect in the Regional Trial Court Decision

The Supreme Court emphasized that Article VIII, Section 14, of the 1987 Constitution requires that “[n]o decision shall be rendered by any court without expressing therein clearly and distinctly the facts and the law on which it is based.” It likewise referred to Rule 120, Section 2, of the 1985 Rules on Criminal Procedure, as amended, which required the written judgment to contain a clearly and distinctly stated statement of the facts proved or admitted by the accused and the law upon which the judgment is based, prepared personally and directly by the judge and signed by him.

The Court held that although a memorandum decision is permitted under certain conditions, a reviewing court cannot satisfy the constitutional mandate by merely referring to the findings of fact and conclusions of law of the lower court. The Regional Trial Court, by peremptorily adopting the municipal court’s decision without adequately stating its own findings and legal basis, rendered a decision described as void for want of the required content. The Supreme Court treated the defect as a nullity. It further warned judges against “lip service” in decision writing, citing its then-recent pronouncement on similarly worded decisions that were “starkly hallow, otiosely written, vacuous in its content and trite in its form.”

Supreme Court’s Disposition on the Conviction

Despite declaring the Regional Trial Court’s decision a nullity, the Supreme Court did not remand for re-compliance because the case had “been pending for sometime.” Instead, it reviewed the evidence and resolved the case on the merits.

The Court relied on the petitioner’s admissions. He admitted having ordered the cutting of the electric, water, and telephone lines of the complainant’s business establishment because those lines crossed his property line. He nonetheless failed to show evidence of the necessary permit or authorization from appropriate authorities to relocate the lines. He also timed the interruption of electric, water, and telephone services during peak hours of the complainant’s business operations.

From those circumstances, the Supreme Court held that the petitioner’s act unjustly annoyed or vexed the complainant and therefore established criminal liability for unjust vexation under Article 287, par. 2, of the Revised Penal Code.

Ruling on Damages and Attorney’s Fees

While the Supreme Court affirmed the conviction, it ruled that the monetary awards lacked legal and evidentiary support. It held that moral damages require proof that they were the proximate result of the defendant’s wrongful act or omission, referring to Article 2217 of the Civil Code, and found no basis for the municipal court’s award in the record as presented. It likewise held that exemplary damages are justified only when the crime is committed with one or more aggravating circumstances, referencing Article 2230 of the Civil Code, and ruled that there was no evidence supporting such aggravating circumstances. Consequently, the Court deleted the awards of moral damages, exemplary damages, and attorney’s fees.

The Court also corrected the penalty terminology previously used by the trial court, noting that “imprisonment for twenty days” was erroneous in light of the Revised Penal Code’s terminology, which is “twenty days of arresto menor.”

Legal Basis and Reasoning

The Supreme Court’s ruling was grounded on the constitutional requirement that judgments contain clearly and distinctly stated findings of fact an

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