GR 114841; (August, 1995) (Digest)
G.R. Nos. 114841-42. August 23, 1995.
ATLANTIC GULF AND PACIFIC COMPANY OF MANILA, INC., petitioner, vs. COURT OF APPEALS, CARLITO D. CASTILLO, HEIRS OF CRISTETA CASTILLO and CORNELIO CASTILLO, respondents.
FACTS
Petitioner Atlantic Gulf and Pacific Company commenced dredging operations in Batangas Bay in 1982 to construct a steel fabrication plant. Private respondents, adjacent landowners, filed consolidated actions for damages. They alleged that petitioner’s personnel and heavy equipment trespassed on their properties, using them as a depot and causing physical damage. Further, the dredging caused sea silt and water to overflow onto their agricultural lands, rendering the soil infertile, salty, and unsuitable for rice cultivation.
The trial court found petitioner liable and awarded compensatory damages, exemplary damages, attorney’s fees, and costs. On appeal, the Court of Appeals affirmed the finding of liability but significantly increased the amounts of compensatory damages awarded to the private respondents. Petitioner then elevated the case to the Supreme Court via certiorari.
ISSUE
Whether the Court of Appeals erred in modifying the trial court’s decision by increasing the award of compensatory damages to the private respondents.
RULING
The Supreme Court modified the appellate court’s decision, reinstating the trial court’s awards for damages. The Court affirmed the factual findings of both lower courts that petitioner was liable for damages due to trespass and the destructive effects of its dredging operations. These factual conclusions, being supported by substantial evidence, are binding and not subject to review in a petition for certiorari under Rule 45, which is limited to questions of law.
However, the Court ruled that the Court of Appeals committed a reversible error in increasing the damage awards. The legal logic is grounded in procedural law regarding the rights of an appellee. The private respondents, as the prevailing parties in the trial court, did not file their own appeal or a cross-appeal questioning the sufficiency of the damages awarded by the trial court. Their inaction constituted acceptance of the trial court’s judgment. An appellee who does not appeal cannot obtain affirmative relief from the appellate court that would modify the judgment in their favor. The appellee’s role is limited to defending the appealed judgment by arguing against the appellant’s claims or upholding the decision on other grounds. Therefore, the Court of Appeals exceeded its authority by granting the private respondents greater relief than what the trial court had provided. Consequently, the Supreme Court reinstated the original awards made by the trial court.