G.R. No. L-51832 April 26, 1989
RAFAEL PATRICIO, petitioner, vs. THE HONORABLE OSCAR LEVISTE, JUDGE, CFI CAPIZ, BRANCH II and BIENVENIDO BACALOCOS, respondents.

FACTS

Petitioner Rafael Patricio, a Catholic priest, was the Director General of the 1976 town fiesta of Pilar, Capiz. On May 16, 1976, during a benefit dance, private respondent Bienvenido Bacalocos, a local official who was intoxicated, struck a beer bottle, injuring his own hand. He then approached Patricio and, without provocation, hit the priest’s face with his bloodied hand, causing a commotion. A criminal complaint for slander by deed was dismissed. Patricio subsequently filed a civil case for damages. The trial court initially ruled in his favor, awarding moral damages, exemplary damages, and attorney’s fees, finding that Bacalocos’s act caused physical suffering, moral shock, and social humiliation.
After the decision was rendered, Bacalocos filed a motion for reconsideration. Patricio contended this motion was a mere scrap of paper because it lacked proper proof of service and notice of hearing, thus the judgment had become final. The trial court, however, entertained the motion, heard oral arguments, and subsequently issued an order dismissing the complaint. The court reversed itself, holding that moral and exemplary damages could not be awarded absent proof of actual or compensatory damages. Patricio filed this petition for review.

ISSUE

The core issues are: (1) whether the trial court lost jurisdiction to reconsider its final decision due to a defective motion for reconsideration; and (2) whether proof of actual or compensatory damages is a prerequisite for an award of moral damages arising from a willful act causing social humiliation.

RULING

The Supreme Court granted the petition, reversed the trial court’s dismissal order, and reinstated the original decision. On the procedural issue, the Court held that while the motion for reconsideration was initially defective for lack of proper service, this defect was cured when the trial court required Patricio to file an opposition and set the matter for oral argument. Patricio was afforded a full opportunity to be heard, which is the essence of due process. The rules of procedure are construed liberally to secure a just determination of every action.
On the substantive issue, the Court ruled that proof of actual or compensatory damages is not necessary for the recovery of moral damages under the circumstances. The act of Bacalocos—publicly and willfully slapping a priest without provocation—is a clear violation of Article 21 of the Civil Code on human relations, which mandates compensation for acts contrary to morals, good customs, or public policy that cause injury. Moral damages are designed precisely to compensate for moral suffering, such as social humiliation, wounded feelings, and similar injuries. The trial court’s initial finding that the act caused physical suffering, moral shock, and social humiliation is a sufficient basis for the award. Furthermore, exemplary damages were properly awarded to serve as a deterrent, and attorney’s fees were recoverable in conjunction with the exemplary damages. The original award was therefore legally sound.