GR 94359; (August, 1991) (Digest)
G.R. No. 94359; August 2, 1991
AYALA INTEGRATED STEEL MANUFACTURING CO., INC., petitioner, vs. HON. COURT OF APPEALS and SEVERINO GO, doing business under the name and style GONING CONSTRUCTION SUPPLY, respondents.
FACTS
Private respondent Severino Go purchased steel materials from petitioner Ayala Integrated Steel Manufacturing Co., Inc. He issued postdated checks as payment. After a fire destroyed his store, Go instructed his bank to stop payment on two checks, prompting Ayala to file criminal complaints for estafa and violation of B.P. Blg. 22. The parties subsequently entered into a settlement agreement wherein Go agreed to pay his balance in installments, and Ayala agreed to return the checks and seek the dismissal of the criminal case. Go complied fully with the payment schedule by December 1981.
Despite the full payment and the prior amicable settlement, Ayala filed another criminal complaint against Go in a different city and initiated a civil case for recovery of the same debt. These complaints were eventually dismissed. Go then filed a civil case for consignation and damages against Ayala, alleging malicious prosecution.
ISSUE
Whether Ayala is liable for moral and actual damages for maliciously prosecuting criminal complaints against Go.
RULING
Yes, Ayala is liable for damages. The Supreme Court affirmed the Court of Appeals’ decision awarding moral and actual damages to Go. The legal logic is grounded on the principle that while individuals have the right to resort to courts, this right must be exercised in good faith and not maliciously. The Court found that Ayala’s actions constituted malicious prosecution.
The elements for estafa and B.P. Blg. 22 were absent. There was no deceit or fraud for estafa, as Go’s initial stop-payment order was due to a fire, and he subsequently fulfilled the settlement agreement. For B.P. Blg. 22, none of the checks issued under the settlement were dishonored. Ayala’s filing of additional criminal and civil actions after full payment and a prior settlement was an oppressive use of the judicial process to harass a debtor, a perversion of the function of the courts. Such bad faith conduct proximately caused Go mental anguish, anxiety, and expenses, warranting compensation through moral and actual damages. The awarded amounts were deemed commensurate with the injury suffered.