Spouses Rufino Co v. Development Bank of the Philippines

Summary

Spouses Co challenged the validity of a foreclosure conducted by Development Bank of the Philippines and subsequent sale to Spouses Edualino, filing suit 20 years after the foreclosure. The Supreme Court denied their petition, finding the complaint was maliciously filed in bad faith. Spouses Co knew of their outstanding bank obligations, the foreclosure proceedings, and could see the school building constructed by Spouses Edualino since 1998, yet waited two decades to challenge the transaction. The Court modified the Court of Appeals' damage awards, deleting all damages to DBP as corporations cannot receive moral damages, and reducing damages to Spouses Edualino for the malicious prosecution they endured. The case establishes that corporations are not entitled to moral damages and reinforces the principle of malicious prosecution under Article 2219(8) of the Civil Code.