Petitioner
Philippine National Bank
Respondent
Court of Appeals (Navarro)
Citation
G.R. No. L-45770
Court
Supreme Court
Division
Third Division
Ponente
Fernan, J.
Decided
March 30, 1988

Whether moral and exemplary damages can be awarded to defendants in a civil case when the plaintiff filed the lawsuit without malice or bad faith

Summary

This case involves Philippine National Bank's lawsuit against employee Napoleon Navarro who defalcated P28,683.77, and the bank's attempt to annul Navarro's sale of property to the Medina spouses as fraudulent. The Medina spouses filed a counterclaim for damages, claiming the lawsuit damaged their reputation. The Supreme Court resolved the inconsistency between the Court of Appeals' finding that PNB acted without malice or bad faith and its award of moral damages to the Medina spouses. Applying Civil Code provisions and established jurisprudence, the Court held that moral damages require a wrongful act, and mere mental anguish from being sued without plaintiff's malice is insufficient. The Court emphasized that litigation is a precious right that cannot be penalized through damage awards absent bad faith, as this would discourage legitimate legal action and open doors to abuse.

Statutes applied

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By Intellegal Editorial Board · March 30, 1988

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