Espero Salao v. The Honorable Court of Appeals

Summary

This civil case involved a petition for review on certiorari of damages awarded for physical injuries. Private respondent Jowie Apolonio sued Espero Salao for head injuries allegedly inflicted with a gun during an incident at Salao's compound on August 24, 1986. The trial court awarded P45,000 total damages based on medical evidence and witness testimony, finding the victim's version more credible. The Supreme Court affirmed the decision, emphasizing that civil liability for quasi-delict under Article 33 of the Civil Code exists independently of criminal prosecution outcomes. The Court also reinforced procedural rules that new issues cannot be raised for the first time on appeal, and confirmed that damage awards must be supported by proper evidence and legal basis.