Petitioner
Ramon Jao Ong
Respondent
Philippine Homing Pigeon Association
Citation
G.R. No. 211752
Court
Supreme Court
Division
First Division
Decided
February 2, 2015

Summary

Ramon Jao Ong sued the Philippine Homing Pigeon Association and its officers for damages arising from delayed release of racing pigeons due to weather conditions, claiming bad faith and abuse of discretion. The Court of Appeals ruled in favor of respondents, finding no bad faith or abuse of discretion. The Supreme Court denied Ong's petition and affirmed the CA decision, emphasizing that damages under Article 19 of the Civil Code require proof of bad faith or malice, which was not established. The Court found that undesirable weather conditions, evidenced by Ong's own news clipping, sufficiently justified the decision to delay the pigeon release. The case clarifies the stringent requirements for proving bad faith in civil damage claims, distinguishing it from mere bad judgment or negligence.

Statutes applied

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By the Intellegal Editorial Board · February 2, 2015

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