Lorena Salvador v. Rafael H · G.R. 241310

Petitioner: Lorena Salvador
Respondent: Rafael H. Hizon
Citation: G.R. No. 241310
Court: Supreme Court
Division: First Division
Decided: October 13, 2021

Summary

Property owner Salvador sustained damages to her duplex unit due to construction and renovation of adjoining unit subleased by HLI. Construction caused cracks on walls and ceiling, and soil erosion in backyard. RTC awarded temperate and moral damages, holding both HLI and its officer Hizon liable. CA dismissed case against Hizon, deleted moral damages, and ordered remand for actual damages determination. Supreme Court partially granted Salvador's petition, awarding reduced temperate and moral damages against HLI only. Court established that temperate damages are proper when actual damage cannot be proved with certainty, and moral damages may be awarded under 'analogous cases' for anxiety and suffering caused by property damage. Corporate officers are not automatically liable for corporate quasi-delicts absent proof of bad faith or malice.

Statutes applied

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By Intellegal Editorial Board · October 13, 2021

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