Lourdes Munsayac v. Benedicta De Lara

Summary

This Supreme Court case involves a passenger injury claim against a jeepney operator where the main issue was the propriety of awarding exemplary damages. The trial court and Court of Appeals awarded exemplary damages based on the owner's failure to placate the injured passenger's suffering after the accident. However, the Supreme Court reversed this aspect, holding that exemplary damages under Article 2232 of the Civil Code require conduct that is coetaneous with and characterizes the breach of contract itself, not subsequent unrelated acts. The Court emphasized that for vicarious liability for exemplary damages, there must be proof that the principal previously authorized or subsequently ratified the agent's wrongful act with full knowledge. The decision clarifies the distinction between compensatory and exemplary damages in common carrier liability cases and establishes that post-breach conduct alone cannot justify exemplary damages without causal connection to the original breach.