G.R. No. 235737 - Spouses Dorao vs. Spouses BBB and CCC

Case Summary (G.R. No. 235737)

Petitioner / Respondent Roles

Petitioners’ position: As parents of Paul, they claim they admonished AAA and Paul pursuant to parental duties (Article 220, Family Code), and deny willfully uttering defamatory words. They asserted reading vulgar text messages allegedly sent by AAA to Paul and contend respondents lack a cause of action.
Respondents’ position: Sought protection of AAA’s right to peaceful life and privacy and recovery of moral and exemplary damages for mental anguish, besmirched reputation, shame and agony suffered by AAA and her parents due to petitioners’ conduct.

Key Dates and Procedural Posture

Underlying incidents: July–November 2004 (minors’ “mutual understanding” and subsequent school encounters).
Trial court Decision: October 28, 2015 — awarded moral damages to AAA, exemplary damages, and attorney’s fees.
Court of Appeals Decision: July 11, 2017 — affirmed trial court. Motion for reconsideration denied in October 26, 2017 Resolution.
Supreme Court review: Petition for Review on Certiorari under Rule 45 filed by petitioners; Supreme Court Decision rendered April 26, 2023. Applicable constitution: 1987 Philippine Constitution.

Material Facts Found by the Trial Court and CA

Recurrent conduct: Petitioners frequented the school, publicly made derogatory comments about AAA (calling her “malandi,” “makati ang laman,” “hindi matino,” accusing her of “dragging” Paul to a restroom), and spread rumors to parents, guardians, and students.
Effect on AAA: Public ridicule, harassment, depression, disengagement from studies and extracurriculars, loss of honor student status and leadership positions, attempted suicide by drug overdose, school transfers, and impaired academic performance.
Witness testimony: School witnesses, notably Arabella Cabading, recounted hearing petitioners’ public derogatory statements and corroborated the humiliation experienced by AAA. The trial court found the testimony credible.

Issues Presented to the Supreme Court

Whether petitioners violated respondents’ and AAA’s rights to dignity, personality, privacy and peace of mind under Articles 21 and 26 of the Civil Code, thereby making them liable for moral and exemplary damages.
Whether the petition was procedurally infirm for non-compliance with Rule 45 and related Supreme Court e-filing directives.

Procedural Compliance and Jurisdictional Requirements

Rule 45 and related Supreme Court e-filing rules require: verified declaration for electronic filings, proof of service of the petition on the lower court and opposing party, and submission of material portions of the record supporting the petition.
The Supreme Court observed that petitioners failed to attach a verified declaration, proof of service, and supporting record excerpts. Such defects are sufficient grounds for dismissal or denial under Rule 45 and Rule 56, and failure to comply with perfection requirements can render an appeal process jurisdictionally defective and the lower judgment final and executory.

Standard and Scope of Review

The Supreme Court reiterated that review under Rule 45 is limited to questions of law; it is not a trier of facts nor empowered to re-evaluate the sufficiency or credibility assessments made by lower courts. Factual findings and credibility assessments of trial courts, especially when affirmed by the Court of Appeals, are accorded great respect and are final absent palpable error or grave abuse of discretion.

Application of Articles 21 and 26, Civil Code

Article 21: obliges compensation where a person willfully causes loss or injury contrary to morals, good customs or public policy.
Article 26: requires respect for dignity, personality, privacy and peace of mind; enumerates examples of acts (prying into private residence, meddling with private life, alienation from friends, vexing or humiliating another) that create causes of action for damages even if not criminal.
The courts found petitioners’ public, defamatory, and humiliating statements about AAA constituted acts contrary to public policy and the dignity of the person, giving rise to liability under Articles 21 and 26.

Child-Protection Legal Framework and Parental Authority

Constitutional and statutory mandates: The 1987 Constitution requires the State to defend the rights of children to assistance and special protection from neglect, abuse, cruelty and other conditions prejudicial to development. The UN Convention on the Rights of the Child and Republic Act No. 7610 (and its implementing rules) expand and define child abuse to include psychological abuse and acts that debase, degrade or demean the intrinsic worth and dignity of a child.
Family Code Article 220 enumerates parental rights and duties but is a duty-based framework; the Court emphasized that petitioners were not AAA’s parents or legal guardians and thus could not claim parental authority over her. Even parental discipline must be reasonable and moderate and must not constitute psychological injury or cruelty as defined in the implementing rules of RA 7610.

Findings on Abuse, Cruelty and Psychological Injury

The Court characterized publicly labeling a 13–14-year-old with sexually derogatory terms before peers, teachers, and parents as harsh, degrading and humiliating; such acts fall within the statutory and policy definitions of psychological cruelty and abuse.
The documented effects on AAA (depression, drop in academic performance, attempted suicide, transfers between schools) constitute psychological injury as contemplated by the implementing rules and support the finding of wrongful conduct causing mental anguish and other nonpecuniary injuries.

Credibility of Witnesses and Weight of Evidence

Trial court and Court of Appeals credited Cabading’s testimony and other witness accounts; petitioners failed to prove bias or motive to discredit Cabading. The Supreme Court deferred to these assessments absent any showing of palpable error or overlooked material facts. The Court reiterated established rules that firsthand observation of witnesses makes trial courts better positioned to determine credibility, and appellate courts should not disturb such findings lightly.

Awards of Moral and Exemplary Damages

Moral damages: Properly awarded to AAA (PHP 30,000) pursuant to Article 2219(10) in conjunction with Articles 21 and 26 because mental anguish, besmirched reputation, wounded feelings and social humiliation were proximate results of petitioners’ wrongful acts. Article 2217’s formulation of recoverable moral damages was applied.
Exemplary damages: Properly awarded (PHP 20,000) to serve as deterrence and vindication where conduct displays willfulness, wantonness, malice, gross negligence or recklessness; exemplary damages aim to punish outrageous conduct and deter similar future abuses. The Court cited established precedent describing exemplary damages’ punitive and deterrent function.

Attorney’s Fees and Interest Adjust

Case Syllabus (G.R. No. 235737)

Facts of the Case

Petitioners are Spouses Melchor and Yolanda Dorao (the Dorao Spouses); respondents are Spouses BBB and CCC, suing by themselves and as natural guardians of their minor daughter AAA.
AAA and Paul (the Doraos' son) were classmates who, unbeknownst to their parents, entered into a special friendship described as a "mutual understanding" sometime in July 2004.
Beginning August 2004, the Dorao Spouses frequented AAA’s school to prevent AAA and Paul from getting closer and, on multiple occasions, publicly displayed strong disapproval of AAA and her parents.
Yolanda allegedly dropped snide remarks to AAA in the presence of classmates and schoolmates, repeatedly calling her a flirt ("malanding babae") and using the phrase "makati ang laman."
Yolanda allegedly called and texted respondent CCC, asserting that AAA took after respondent-CCC and describing AAA with terms including "puta," "malandi," and "makati ang laman."
Melchor is alleged to have publicly accused AAA of "dragging his son [Paul] to [a] restroom" and uttered other derogatory remarks in front of parents and students during a parents’ meeting and other school occasions.
As a result of these imputations and public humiliations, AAA reportedly felt harassed, intimidated, ridiculed, and humiliated; she experienced depression, disengaged from studies and extracurricular activities, lost academic distinction and leadership positions, attempted suicide by drug overdose, dropped out of her school, and transferred to another university.
Respondents alleged violations of their family’s right to a peaceful life and privacy and claimed sleepless nights, besmirched reputation, shame, and agony. They prayed for moral damages (aggregate P100,000.00) and exemplary damages (P50,000.00) among other reliefs.
Petitioners denied the allegations, claiming they read vulgar text messages allegedly sent by AAA to Paul (texts included "I miss your kiss," "I miss your kissable lips," and "(h)indi ako makatulog kasi ikaw lang ang nasa isip ko") and merely admonished AAA as part of their parental duty to their own son; they contended respondents had no cause of action and that AAA’s academic decline was her own fault or a consequence of her parents tolerating her alleged misdeeds.

Procedural History

Complaint filed in the Regional Trial Court (Civil Case No. 740) by Spouses BBB and CCC to protect AAA’s right to a peaceful life and privacy and to recover damages for public humiliation and rumor-spreading.
October 28, 2015: The Regional Trial Court rendered judgment in favor of respondents, awarding moral damages to AAA (PHP30,000.00), exemplary damages (PHP20,000.00), and attorney’s fees & litigation expenses (PHP30,000.00), with joint and several liability imposed on the Dorao Spouses.
The Court of Appeals, in a July 11, 2017 Decision (CA-G.R. CV No. 106749), affirmed the trial court’s Decision and assessed costs against the Dorao Spouses; a subsequent October 26, 2017 Resolution denied the Dorao Spouses’ motion for reconsideration.
The Dorao Spouses filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, challenging the Court of Appeals’ Decision and Resolution.
The Supreme Court considered both procedural defects in the Petition (absence of verified declaration, proof of service, and supporting record portions) and the substance of the case, and issued its decision on April 26, 2023.

Issues Presented to the Supreme Court

Whether petitioners Spouses Dorao violated the dignity, personality, privacy, and peace of mind of respondents Spouses BBB and CCC and their minor daughter AAA, thereby rendering themselves liable for moral and exemplary damages under Articles 21, 26, and Article 2219(10) of the Civil Code.
Whether the Petition for Review should be dismissed on procedural grounds for failure to comply with Rule 45 and related Supreme Court requirements for electronic filing and contents.
Whether the factual findings and credibility assessments of witnesses by the lower courts were tainted by reversible error such that this Court should re-evaluate the sufficiency of evidence.

Petitioners’ Principal Contentions

Petitioners persistently denied uttering defamatory words to AAA and denied willfully causing damage to respondents.
They asserted that the texts they read justified admonition and were part of their parental duty toward their son Paul under Article 220 of the Family Code.
Petitioners contended they merely advised both minors to study hard and understood their actions as exercising parental authority aimed at protecting their son’s moral development.
They challenged the credibility of respondent witnesses, particularly Arabella Cabading, alleging inconsistent or inaccurate recollection and bias.
Petitioners argued respondents lacked cause of action and therefore they should not be liable for moral or exemplary damages.

Respondents’ Principal Claims and Proof

Respondents maintained petitioners engaged in harassment, intimidation, humiliation, and spreading false malicious rumors against AAA in public settings (school), thereby trampling her dignity, personality, privacy, and peace of mind.
Respondents emphasized the trauma and adverse educational consequences suffered by AAA: depression, attempted drug overdose, drop out and successive transfers, loss of honor roll distinction and leadership.
Respondents relied on witness testimony, including detailed accounts by AAA, respondent-CCC, and Arabella Cabading, to prove the sequence of public derogatory statements, the contexts in which they were made (parents’ meetings, school corridors, rehearsals), and the observable effects on AAA’s behavior and academic records.
Respondents argued moral damages were warranted under Articles 21 and 26, and Article 2219(10) of the Civil Code, and exemplary damages were appropriate to punish and deter willful and humiliating conduct.

Evidence and Witness Testimonies Emphasized by Lower Courts

Testimony of AAA describing repeated public shaming by Yolanda (statements like "malandi kang babae," "makati ang laman"), pervasive presence of Yolanda in school, classmates’ reactions and ridicule, decline in grades and standing, and incidents leading to drug overdose and school transfer.
Testimony of respondent-CCC concerning phone calls and texts from Yolanda using derogatory expressions, turning off her phone to avoid further insults, details of AAA’s overdose on August 5 and subsequent hospital treatment, and the effects on AAA’s studies and reputation.
Testimony of Arabella Cabading recounting attendance at the November 30, 2004 parents’ meeting (card giving day), hearing Melchor make harsh statements about AAA (terms "malandi" and "makati ang laman" and allegation of being pulled to the comfort room), hearing Yolanda call AAA "hindi matino ang babaing yan," and Cabading’s reaction that the treatment of a minor was unfair and that guidance counseling was the proper remedy.
Documentary references to AAA’s Second Year Report Card and Secondary Student’s Permanent Record indicating decline in grades, and corroboration of sequence of events in school.

Findings and Rationale of the Regional Trial Court and Court of Appeals

Both courts credited the testimonies of AAA, respondent-CCC, and Cabading, finding the Dorao Spouses publicly humiliated, denigrated, and spread malicious rumors about AAA.
The trial court found that petitioners’ willful acts were contrary to morals, good customs or public policy and caused loss and injury to AAA, warranting damages under Articles 21 and 26 and moral damages under Article 2219.
The Court of Appeals affirmed the trial court, stressing the willful public humiliation and degradation of AAA’s dignity as basis for the award of damages, including moral and exemplary damages and attorney’s fees.
The courts afforded great weight to the