- Petitioner
- Joyce
- Respondent
- Ardiente
- Citation
- G.R. No. 161921
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Peralta, J.
- Decided
- July 17, 2013
Summary
Joyce Ardiente sold her property to Ma. Theresa Pastorfide in 1994 with agreement that Pastorfide would assume water/power bills. In 1999, Ardiente requested COWD to disconnect Pastorfide's water supply without notice, claiming non-compliance with account transfer obligation. COWD disconnected service without proper notice despite bills not yet due. Supreme Court affirmed lower courts' finding of abuse of rights under Civil Code Article 19, holding all defendants solidarily liable for damages. The case established that exercise of legal rights must observe justice, good faith, and proper purpose - rights exercised in bad faith causing harm to others result in liability for damages. Court awarded reduced moral and exemplary damages plus attorney's fees, emphasizing deterrent effect against socially deleterious actions.
Intellegal Wiki · Key Holding
Denied the petition and affirmed the CA, finding an abuse of rights under Civil Code Article 19 where a water disconnection was requested and carried out without notice; held the defendants solidarily liable under Articles 20-21, with moral damages under Article 2219, exemplary damages under Article 2229, and attorney's fees under Article 2208.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.