- Petitioner
- Titus B. Villanueva
- Respondent
- Emma M. Rosqueta
- Citation
- G.R. No. 180764
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Abad, J.
- Decided
- January 19, 2010
Summary
This case involves a civil damages action based on abuse of right under the Civil Code. Deputy Commissioner Emma Rosqueta of the Bureau of Customs filed for damages against Commissioner Titus Villanueva for allegedly preventing her from performing her duties and excluding her from official recognition despite a preliminary injunction ordering her reinstatement. The Supreme Court applied the abuse of right principle under Articles 19, 20, and 21 of the Civil Code, finding that Villanueva acted in bad faith by ignoring the court's injunction order and maliciously excluding Rosqueta from the Bureau's centennial commemorative materials. The Court awarded reduced damages of P200,000.00 moral damages, P50,000.00 exemplary damages, and P50,000.00 attorney's fees, emphasizing that moral damages should reasonably approximate the extent of hurt caused and the gravity of the wrong done.