Government Service Insurance · G.R. 135644

Petitioner: Government Service Insurance System
Respondent: Spouses Gonzalo
Citation: G.R. No. 135644
Court: Supreme Court
Division: First Division
Ponente: Pardo, J.
Decided: September 17, 2001

Summary

Spouses Deang obtained a housing loan from GSIS secured by real estate mortgage, depositing their property title as required. After paying the loan early in 1979, they requested title return to secure another loan, but GSIS had negligently lost the document. Despite GSIS's reconstitution efforts, the delay prevented the spouses from obtaining their intended private loan. The Supreme Court ruled GSIS liable under contractual principles rather than quasi-delict, as a pre-existing loan agreement existed. The Court applied Civil Code provisions on contractual obligations, finding GSIS liable as an obligor in good faith for natural and probable consequences of breach. The Court awarded P20,000 in temperate damages, recognizing pecuniary loss that could not be precisely quantified, but deleted attorney's fees for lack of proper justification. This case clarifies GOCC liability and distinguishes between contractual and tortious obligations in determining damages.

Statutes applied

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By Intellegal Editorial Board · September 17, 2001

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