Case Summary (G.R. No. 235737)
Procedural History
BBB and CCC filed in the RTC a complaint for damages, alleging invasion of the family’s right to peaceful life and privacy and seeking P100,000 moral and P50,000 exemplary damages. The RTC (Oct. 28, 2015) awarded AAA P30,000 moral damages, exemplary P20,000, and P30,000 attorneys’ fees. The CA (July 11, 2017) affirmed. The petitioners’ motion for reconsideration was denied (Oct. 26, 2017). A petition for review on certiorari to the Supreme Court followed.
Issues Presented
- Procedural compliance with Rule 45 and e-filing requirements
- Substantive liability for willful harassment, defamation, and invasion of AAA’s dignity, personality, privacy, and peace of mind
Procedural Ruling
The petitioners failed to attach a verified declaration, proof of service, and material portions of the record as required by Rule 45 and the Supreme Court’s e-filing circulars. These jurisdictional defects warranted dismissal. However, the Court also proceeded to review the merits and found no reversible error.
Merits and Legal Basis
- Under Civil Code Article 21, any person who willfully causes injury contrary to morals or public policy must compensate for damages.
- Article 26 protects a person’s dignity, privacy, and peace of mind; public humiliation and malicious rumors give rise to a cause of action.
- Republic Act 7610 and the UN Convention on the Rights of the Child enshrine the State’s duty to shield children from psychological abuse and cruelty.
- Parental authority (Family Code Articles 209, 220) must be exercised within bounds of respect for the child’s human dignity; petitioners are neither the child’s parents nor legal guardians.
Findings on Credibility and Factual Determinations
The RTC and CA credited consistent eyewitness testimony (including that of Arabella Cabading) regarding the Dorao Spouses’ repeated public insults and rumors. Petitioners failed to prove any bias or misapprehension by the trial courts in assessing credibility. As a matter of fact, AAA suffered depression, academic loss, social rejection, and an attempted overdose directly linked to the harassment.
Award of Damages
- Moral damages: PHP 30,000.0
Case Syllabus (G.R. No. 235737)
Facts
- Petitioners Spouses Melchor and Yolanda Dorao are the parents of Paul, then-boyfriend of minor AAA, daughter of Spouses BBB and CCC.
- In July 2004, AAA and Paul—both minors—entered into a “mutual understanding” friendship without their parents’ knowledge.
- Beginning August 2004, the Dorao Spouses began frequenting AAA’s school to interfere with her relationship with Paul.
- Yolanda Dorao publicly called AAA derogatory names (“malandi,” “makati ang laman,” “puta”) before classmates and texted CCC with similar allegations.
- BBB asked Melchor to restrain Yolanda; the harassment continued, prompting BBB and CCC to avoid school activities.
- On November 30, 2004, at a Parents’ Meeting, Melchor accused AAA of dragging Paul to a restroom and repeated insults; Yolanda joined in the public ridicule.
- AAA suffered harassment, intimidation, and public humiliation, leading to depression, loss of honor-student status, withdrawal from school activities, a suicide attempt by drug overdose, and school transfers.
- BBB and CCC alleged violation of AAA’s and their own rights to peaceful life and privacy, seeking moral (₱100,000) and exemplary (₱50,000) damages.
- The Dorao Spouses denied wrongdoing, claiming parental duty under Article 220 of the Family Code and contending AAA and her parents had no cause of action.
Procedural History
- October 28, 2015: RTC Branch 34, La Union, ruled in favor of BBB and CCC, holding the Dorao Spouses jointly and severally liable for:
• ₱30,000 moral damages to AAA
• ₱20,000 exemplary damages
• ₱30,000 attorney’s fees and litigation expenses - July 11, 2017: Court of Appeals (CA) affirmed the RTC Decision and February 5, 2016 Resolution, finding no abuse of discretion in awarding damages.
- October 26, 2017: CA denied the Dorao Spouses’ motion for reconsideration.
- The Dorao Spouses filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issue
- Whether the Dorao Spouses violated the dignity, personality, privacy, and peace of mind of AAA and her parents, thereby justif