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G.R. No. 120706 – 324 SCRA 85 – Civil Law – Torts and Damages – Human Relations – Article 26 – “Human Personality Exalted By Laws”
The spouses Nestor and Allem Nicolas were the lessees of Florence Concepcion. The spouses were engaged in an office supply business where they cater to various government agencies. In 1985, the spouses agreed to let Florence in on the business. Hence, Florence contributed capital.
But sometime in July 1985, Rodrigo Concepcion, the brother of the dead husband of Florence, called Florence interrogating her about the rumored affair that she was having with Nestor. Florence denied the said rumor. Unsatisfied, Rodrigo met with Nestor face-to-face. Nestor denied the allegations of Rodrigo. Rodrigo then dared Nestor to meet the neighbors, friends, and relatives, who allegedly know of the relationship. Nestor agreed. And so in front of these neighbors, friends, and relatives, Rodrigo reiterated his allegations but then these neighbors, friends, and relatives denied having ever known any illicit affair between Nestor and Florence.
Because of the incident, Nestor felt debased so much so that he was ashamed of going out in public. As a result, his business started to decline. Florence also stopped contributing capital. Even his wife started doubting his fidelity. Nestor then wrote a letter to Rodrigo asking him to publicly apologize for the incident as well as to pay the spouses damages. Rodrigo refused hence he was sued by the spouses. The trial court as well as the Court of Appeals ruled in favor of the spouses and awarded in their favor a total of P85k in moral and exemplary damages as well as attorney’s fees.
On appeal, Rodrigo insisted that there was no legal basis for the award of damages against him because the acts complained of are not those found in Article 26 and Article 2219 of the Civil Code.
ISSUE: Whether or not the award of damages is proper.
HELD: Yes. The provisions of Articles 26 and 2219 are as follows:
Art. 26. Every person shall respect the dignity, personality, privacy and peace of mind of his neighbors and other persons. The following and similar acts, though they may not constitute a criminal offense, shall produce a cause of action for damages, prevention and other relief: (1) Prying into the privacy of another’s residence; (2) Meddling with or disturbing the private life or family relations of another; (3) Intriguing or humiliating another on account of his religious beliefs, lowly station in life, place of birth, physical defect, or other personal condition.
Art. 2219. Moral damages may be recovered in the following and analogous cases: (1) A criminal offense resulting in physical injuries; (2) Quasi-delicts causing physical injuries; (3) Seduction, abduction, rape or other lascivious acts; (4) Adultery or concubinage; (5) Illegal or arbitrary detention or arrest; (6) Illegal search; (7) Libel, slander or any other form of defamation; (8) Malicious prosecution; (9) Acts mentioned in Art. 309 (referring to disrespect for the dead or wrongfully interfering in a funeral); (10) Acts or actions referred to in Arts. 21, 26, 27, 28, 29, 30, 32, 34, and 35 x x x x
Certainly, what Rodrigo did is a violation of Nestor’s person. The Supreme Court went on to explain the rationale behind Article 26 and why the enumerations therein are not exclusive: The Code Commission stressed in no uncertain terms that the human personality must be exalted. The sacredness of human personality is a concomitant consideration of every plan for human amelioration. The touchstone of every system of law, of the culture and civilization of every country, is how far it dignifies man. If the statutes insufficiently protect a person from being unjustly humiliated, in short, if human personality is not exalted – then the laws are indeed defective. Thus, under this article, the rights of persons are amply protected, and damages are provided for violations of a person’s dignity, personality, privacy and peace of mind.