GR 91201; (December, 1991) (Digest)
G.R. No. 91201 December 5, 1991
Eustaquio Mayo y Agpaoa, petitioner, vs. People of the Philippines, respondent.
FACTS
Petitioner Eustaquio Mayo, a bus driver, was convicted of Reckless Imprudence Resulting in Damage to Property with Multiple Physical Injuries. The incident occurred on August 7, 1982, along MacArthur Highway in Mabalacat, Pampanga. Mayo, driving a Philippine Rabbit bus, attempted to overtake a Mitsubishi Lancer car driven by June Navarette. While abreast of the Lancer, an oncoming vehicle approached. To avoid a head-on collision, Mayo swerved back to the right lane, striking the Lancer’s left rear portion. The impact caused the Lancer to lose control, hit a pedestrian, and crash into a concrete fence. The Lancer was heavily damaged, and its passengers, including Linda Navarette, sustained various injuries. The trial court convicted Mayo and, in the criminal case’s civil aspect, awarded Linda Navarette P700,000.00 as moral damages, which the Court of Appeals affirmed.
ISSUE
Whether the award of P700,000.00 as moral damages to Linda Navarette is excessive and unconscionable.
RULING
Yes, the award is excessive. The Supreme Court modified the award, reducing the moral damages to P200,000.00. The legal logic is anchored on the principle that moral damages, while not intended for enrichment, must be reasonable and proportionate to the suffering endured. The Court emphasized that such damages are meant to compensate for physical suffering, mental anguish, and similar injuries, not to impose a penalty. In assessing reasonableness, the Court considers the factual circumstances, including the nature and consequences of the plaintiff’s injuries. Here, while Linda Navarette suffered significant injuries, including facial disfigurement and loss of vision in one eye, the original award far exceeded what was just and temperate. The Court found that an award of P200,000.00 was commensurate with the suffering and injury proven, aligning with jurisprudence that mandates moderation. The reduction ensures the award serves its compensatory purpose without being punitive or oppressive.