G.R. No. 177250 , 177422, 177676 November 28, 2016
ROSITA B. LIM, ET AL. vs. LUIS TAN, ET AL. (Consolidated Cases)

FACTS

This case originated from the murder of Florentino Lim in 1973. Several individuals, including respondents Luis Tan, Ang Tiat Chuan, and others (the Tan brothers), were charged. A Military Commission convicted Luis Tan and Chuan, among others, of murder, while some co-accused, including other Tan brothers, were acquitted. In 1983, the victim’s heirs (petitioners) filed a civil action for damages against all those originally charged. The Regional Trial Court (RTC) awarded massive damages totaling over ₱51 million against the defendants jointly and severally.
On appeal, the Court of Appeals (CA) significantly modified the award. It held only the convicted individuals (Luis Tan, Chuan, and their four co-accused) jointly and severally liable, absolving the acquitted Tan brothers. The CA reduced the damages to ₱50,000 as civil indemnity, ₱350,000 as temperate damages, ₱150,000 as moral damages, ₱150,000 as exemplary damages, ₱100,000 attorney’s fees, and ₱100,000 litigation expenses. Both parties sought review before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in modifying the amounts of damages, attorney’s fees, and litigation expenses awarded to the heirs of the victim.

RULING

The Supreme Court affirmed the CA’s modified awards with one adjustment to the civil indemnity. The core legal principle is that in crimes resulting in death, recoverable damages include civil indemnity, actual or compensatory, moral, and exemplary damages, plus attorney’s fees and litigation expenses. The Court emphasized that the determination of these amounts, while generally factual, was reviewed to finally resolve the long-pending case.
The Court upheld the CA’s reductions, finding the lowered amounts for temperate, moral, and exemplary damages, as well as attorney’s fees and litigation expenses, to be in accord with prevailing jurisprudence and the evidence presented. However, it modified the civil indemnity from ₱50,000 to ₱100,000. The legal logic for this increase rests on the heinous nature of the crime—murder—and the penalty prescribed by law at the time of its commission. Civil indemnity is mandatory and granted without need of proof other than the fact of death as a result of the crime. Following contemporary jurisprudence, the standard indemnity for murder is ₱100,000. The Court also imposed legal interest of six percent per annum on all awarded damages from the finality of the decision until full payment. Thus, the petition was partly meritorious.