G.R. No. 235737. April 26, 2023.
SPS. MELCHOR AND YOLANDA DORAO, PETITIONERS, VS. SPS. BBB AND CCC, BY THEMSELVES AND AS NATURAL GUARDIANS OF THEIR MINOR DAUGHTER, AAA, RESPONDENTS.

FACTS

Petitioners Spouses Melchor and Yolanda Dorao are the parents of Paul, the then-boyfriend of AAA, the minor daughter of respondent Spouses BBB and CCC. Unbeknownst to their parents, AAA and Paul, both students at a school in La Union, entered into a relationship in July 2004. Beginning August 2004, the Dorao Spouses frequented the school to prevent the relationship. Yolanda Dorao made derogatory remarks about AAA in public, calling her a flirt (“malanding babae” and “makati ang laman”) and, via calls and texts to AAA’s mother, a woman with loose morals (“puta”). Despite a request from AAA’s father to desist, the harassment continued. During a Parents’ Meeting on November 30, 2004, which AAA’s family avoided, the Dorao Spouses spread rumors among other parents and students, claiming AAA preyed on boys and had dragged their son to a restroom. Melchor Dorao also publicly called AAA flirty and sexually aggressive. As a result, AAA suffered depression, lost her academic standing as an honor student and leader, attempted suicide by drug overdose, dropped out, and transferred schools. Her parents claimed damages for violation of their family’s right to privacy and peace of mind. The Dorao Spouses defended their actions as a parental duty to admonish AAA for inappropriate behavior, such as sitting on Paul’s lap, based on vulgar text messages they read.

ISSUE

Whether petitioners Spouses Dorao violated the right to the dignity, personality, privacy, and peace of mind of respondents Spouses BBB and CCC and their minor daughter, AAA, making them liable for moral and exemplary damages.

RULING

Yes. The Supreme Court denied the petition, affirming the lower courts’ rulings. Procedurally, the petition was defective for lack of a verified declaration, proof of service, and supporting record portions, grounds for dismissal under Rules 45 and 56. Substantively, the Court found no reversible error. The Dorao Spouses’ acts of publicly humiliating, degrading, and spreading false rumors about AAA constituted willful acts contrary to morals, good customs, and public policy under Articles 21 and 26 of the Civil Code. Their claim of acting under parental duty (Article 220, Family Code) did not justify cruel or degrading punishment that belittles or humiliates a child, violating the child’s human dignity. The awards of moral damages (PHP30,000.00 to AAA), exemplary damages (PHP20,000.00), and attorney’s fees & litigation expenses (PHP30,000.00) were upheld as the Dorao Spouses’ actions directly caused AAA’s mental suffering, trauma, and academic decline.