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COASTAL PACIFIC TRADING ROLLING MILLS, INC.

Facts:

vs.

SOUTHERN

TANAY RECREATION CENTER AND DEVELOPMENT CORP., vs. CATALINA FAUSTO AND ANUNCIACION FAUSTO PACUNAYEN Facts:

Visayan Integrated Steel Corporation or VISCO was formerly known as Sounthern Rolling Mills, Inc. VISCO entered into a processing agreement with Petitioner Coastal. The parties agreed that Coastal would deliver 3,000 metric tons of hot rolled steel coils to VISCO for processing in to block iron sheets. However, VISCO was able to process and deliver to Coastal only 1, 600 metric tons of the said sheets. Hence , a total of 1,400 metric tons of hot rolled coils remained unclaimed for. Then a year later, Coastal filed with the RTC a Complaint for Recovery of Property and Damages. It alleged that VISCO had fraudulently misapplied or converted the finished steel entrusted to it. Issue: W/N Coastal is liable for moral damages.

Tanay Recreation leased the property owned by Catalina Fausto under a Contract of Lease. The contract also provided that should Fausto decides to sell the property, Tanay shall have the priority right to purchase same. Thereafter, Fausto;s daughter Respondent Pacunayan informed Tanat to remove the improvements built on the property leased. Tanay found out that the property was sold to Pacunayan. Tanay filed a complaint for annulment of Deed, Specific Performance with Damages. The lower Courts dismissed Tanays claim for Damages. Issue: W/N Tanay Recreation is entitled to moral damages and exemplary damages. Ruling: No.

Ruling: NO. As a rule, a corporation is not entitled to moral damages because, not being a natural person, it cannot experience physical suffering or sentiments like wounded feelings, serious anxiety, mental anguish and moral shock. The only exception to this rule is when the corporation has a good reputation that is debased, resulting in its humiliation in the business realm. In the case at bar, the records did not show any evidence that the name or reputation of Coastal was dishonored as a result of the fraudulent acts complained by Coastal. Hence, Coastal is not entitled to moral damages. The award of moral damages cannot be granted in favor of a corporation because, being an artificial person and having existence only in legal contemplation, it has no feelings, no emotions, no senses. It cannot, therefore, experience physical suffering and mental anguish, which can be experienced only by one having a nervous system. Hence, Tanay being a corporation cannot be entitled to moral damages. For the claim of exemplary damages, it is a requisite in the grant that the act of the offender must be accompanied by bad faith or done in wanton, fraudulent or malevolent manner. Moreover, when a party is not entitled to actual or moral damages an award of exemplary damages cannot also be awarded. In this case, Tanay failed to show that respondent acted in bad faith, or in wanton, fraudulent or malevolent manner.

PEOPLE OF THE PHILIPPINES vs. OLITA Facts: Olita was charges with the crime of Robbery with Homicide for feloniously taking, stealing and carrying away the cash money of representing the Meralco collections of Isagani Tongco against his will and for the killing of latters security escort, Romeo Pacle. Olita entered a plea of not guilty. The trial court convicted him. Among the trial courts judgment was that Olita is liable to indemnify the heirs od Pacle the amount of P30, 000 as moral damages. Issue: W/N the heirs of victim Pacle are entitled to claim moral damages. Ruling: No. Moral damages cannot be awarded in the absence of any factual basis. There must be pleasing and proof of moral suffering, mental anguish, fright, wounded feelings and similar injury. In this case, the SC finds no basis from the record to justify the awards of moral damages in favor of the heirs of Romeo Pacle. Thus, the heirs are not entitled to claim moral damages.

then, sent TEC another demand letter for the payment of the differential billing. TEC paid under protest. TEC, then, filed a complaint for damages against Meralco and Ultra before the RTC of Pasig. RTC ruled that Meralco failed to prove that TEC was guilty if tampering the meter installations. That TEC was entitled to claim moral and exemplary damages from Meralco. The CA affirmed RTCs ruling. ISSUE: W/N TEC is entitled to moral and exemplary damages. RULING: NO moral damages but YES to exemplary damages. As a rule, a corporation is not entitled to moral damages because, not being a natural person, it cannot experience physical suffering or sentiments like wounded feelings, serious anxiety, mental anguish and moral shock. The only exception to this rules is when the corporation has a reputation that is debased, resulting in its humiliation in the business realm, provided, that the claimant must present proof to justidy the award. It is important to prove the existence of the factual basis of the damage and its causal relation to Meralcos acts. In this case, there was no evidence that the name of TEC has been debased as a result of Meralcos acts. Further, the trial court stated no basis for the award of the moral damages. Hence, TEC is not entitled to moral damages. However, TEC is entitled to exemplary damages. Exemplary damages are imposed by way of example of correction for the public good in addition to moral, temperate, liquidated or compensatory damages. In this case, to serve as an example that before a disconnection of electrical supply can be done, the requisites of the law must first be complied with. Hence again, the award of exemplary damages to TEC were proper.

MANILA ELECTRIC COMPANY CELECTRIC CORPORATION Facts:

vs.

T.E.A.M

TEC entered into a Contract of Lease with Ultra for the use of Ultras DCIM building for a period of 5 years. Then, a team Meralcos inspectors conducted a surprise inspection of the electric meters installed at the DCIM building as witnessed by Ultras representative. The inspectors found two meters were tampered with and did not register the actual power consumption in the building. Meralco informed TEC of the results of the inspection and demanded for the payment of amount of the unregistered consumption as a result of the tampering of the meters. TECs management referred the letter to Ultra. Eventually, Meralco disconnected the electricity supply to the DCIM building for failure of TEC to pay the amount demanded. TEC denied the tampering. It filed a complaint before the ERB praying that electric power be restored to the DCIM building. ERB ordered for the reconnection. Meanwhile, Meralco conducted another inspection in TECs another building, the NS building. It alleged that the meters were not registering the correct power consumption. Meralco,

Equitable Leasing Corporation vs. Lucita Suyom, Marissa Enano, MyrnaTamayo and Felix Oledan [G.R. No. 143360, 5 September 2002, 388 SCRA 445] Facts: A tractor driven by Raul Tutor rammed into a housecum-store in Tondo, Manila. Part of the house was destroyed. Two people died and four were injured. Tutor was convicted of reckless imprudence resulting in multiple homicide and multiple physical injuries. Verification with the Land Transportation Office revealed that the registered owner of the tractor was Equitable Leasing Corporation who leased it to Edwin Lim. The relatives of the victims filed a civil case for damages. The Regional Trial Court ruled against Equitable and ordered it to pay damages to the victims relatives. Upon Equitables appeal, the Court of Appeals sustained the RTC. Equitable filed a petition for review with the Supreme Court. Issue: Whether Equitable Leasing is liable for damages Held/Ratio: Yes, Equitable Leasing is liable. The petition is denied and the CA decision is affirmed. As the registered owner of the tractor, Equitable Leasing is liable for the acts of Raul Tutor even if he was actually the employee of Equitables former lessee, Ecatine Corporation, who became the actual owner of the tractor by virtue of a deed of sale not registered with the LTO. Regardless of sales made of a motor vehicle, the registered owner is the lawful operator insofar as the public and third persons are concerned; consequently, it is directly and primarily responsible for the consequences of its operation. In the eyes of the law, the owner/operator of record is the employer of the driver, the actual owner/operator being considered as merely the agent of the registered owner/operator. The principle applies even if the registered owner of any vehicle does not use it for public service. The main aim of motor vehicle registration is to identify the owner so that if any accident happens, or any damage or injury is caused by the vehicle, responsibility can be fixed on a definite individual, the registered owner. Failure to register the deed of sale should not prejudice victims, who have the right to rely on the principle that the registered owner is liable for damages caused by the negligence of the driver. Equitable Leasing cant hide behind the allegation that Tutor was Ecatine Corps employee, because it will prevent victims from recovering their loss on the basis of Equitables inaction in failing to register the sale. The non-registration is Equitables fault, which should face the legal consequences thereof.

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