Civil Law,  Legally Yours

Del Castillo Case Doctrines (Civil Law – Torts and Damages)

Del Castillo Case Doctrines

Summaries of case doctrines penned by Justice Del Castillo.

Civil Law Torts and Damages

Adrian Wilson International Associates, Inc. v. TMX Philippines, Inc.
G.R. No. 162608, July 26, 2010

Actual damages may be claimed for the natural and probable consequences of the breach of contract.

Calibre Traders, Inc. v. Bayer Philippines, Inc.
G.R. No. 161431, October 13, 2010

The burden of proving bad faith as a ground for claiming damages rests on the party alleging the same.

Ching v. Bantolo
G.R. No. 177086, December 5, 2012

Exemplary damages under Article 2229 of the Civil Code are not recoverable as a matter of right. They are awarded only if the guilty party acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner (not merely bad faith).

Crisostomo v. People of the Philippines
G.R. No. 171526, September 1, 2010

In robbery with homicide, civil indemnity and moral damages in the amount of P50,000.00 is mandatory without the need of allegation and evidence other than the fact of death of the victim from the commission of the crime.

Del Carmen, Jr. v. Bacoy
G.R. No. 173870, April 25, 2010

The registered owner of a vehicle is directly and primarily liable for injuries caused by the operation of the same. Absent the circumstance of unauthorized use, or that the subject vehicle was stolen which are valid defenses to a registered owner, the latter cannot escape liability for the quasi-delict resulting from the vehicle’s use.

Duenas v. Guce-Africa
G.R. No. 165679, October 5, 2009

Before actual damages may be awarded, there must be competent proof of the actual amount of loss. Credence can be given only to claims which are duly supported by receipts.

Greenstar Express, Inc. v. Universal Robina Corporation
G.R. No. 205090, October 17, 2016

In cases where both the registered-owner rule and Article 2180 apply, the plaintiff must first establish that the employer is the registered owner of the vehicle in question. Once the plaintiff successfully proves ownership, there arises a disputable presumption that the requirements of Article 2180 have been proven.

Metropolitan Bank and Trust Company v. Rosales
G.R. No. 183204, January 13, 2014

In cases of breach of contract, moral damages may be recovered only if there is bad faith or gross negligence amounting to bad faith in the performance of contractual obligations.

One Network Rural Bank Inc. v. Baric
G.R. No. 193684, March 5, 2014

A third party who did not commit a violation or invasion of the aggrieved party’s rights may not be held liable for nominal damages.

Orix Metro Leasing and Finance Corporation v. Ong
G.R. Nos. 174089; 174266, January 25, 2012

The registered owner shall be liable for the damages for the negligent operation of the vehicle which is registered in his name regardless of the actual owner of such vehicle (Registered Owner Rule).

People of the Philippines v. Villar
G.R. No. 202708, April 13, 2015

Damages for loss of earning capacity may be awarded in two instances:
1) the victim was self-employed and receiving less than the minimum wage under the current laws and no documentary evidence is available in the decedent’s line of business; and
2) the deceased was employed as a daily wage worker and receiving less than the minimum wage.

Recoverable actual damages must be proved with reasonable degree of certainty.

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