G.R. No. 244054, April 26, 2023
Gloria F. Quiroz, Petitioner, vs. Ramon R. Nalus, Respondent.

FACTS

The Supreme Court, by a Resolution dated March 11, 2020, denied Gloria Quiroz’s petition and affirmed the Court of Appeals’ decision which deleted the trial court’s award of damages from its judgment on the pleadings. The Court held that in a judgment on the pleadings, an award of moral damages requires justification and cannot be granted without proof of its factual basis and causal connection to the act complained of; consequently, exemplary damages are also unwarranted. Quiroz filed a motion for reconsideration, reiterating her plea to restore the trial court’s award of damages without further proof, citing cases where damages in judgments on the pleadings were upheld because the defendants did not object to the motions and were deemed to have admitted the factual allegations. Alternatively, she prayed for the case to be remanded to the trial court for presentation of evidence to prove her claim for damages, as Nalus could no longer comply with the order to deliver back possession of the property as it was now leased to a third party. Ramon Nalus, in his comment, asserted that a claim for damages is not deemed admitted even if not specifically denied and that Quiroz failed to present proof as she opted for a judgment on the pleadings.

ISSUE

Should Gloria Quiroz be allowed to prove the damages she claims to have suffered arising from Ramon Nalus’s contractual breach?

RULING

Yes. The motion for reconsideration is meritorious. The Supreme Court ruled to partially grant the motion and modify its earlier Resolution. The Court held that while Nalus is deemed to have admitted his contractual breach by not specifically denying it, the resulting damages claimed by Quiroz are not deemed admitted. Citing Swim Phils., Inc. v. CORS Retail Concept, Inc. and Raagas v. Traya, the Court emphasized that even if allegations regarding the amount of damages are not specifically denied, such damages are not deemed admitted; actual damages must be proved and cannot rely on speculation. The cases cited by Quiroz (Santiago and Tropical Homes) were found inapplicable as they involved stipulated values or agreed payment schemes, eliminating the need for further evidence. In the present case, there was no such stipulation or admission on the extent of damages. Consequently, in the higher interest of substantial justice, the case is remanded to the Regional Trial Court for reception of evidence to determine the precise extent of damages Quiroz claims to have sustained due to Nalus’s contractual breach.