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Crystal v. BPI

The heirs of Raymundo and Desamparados Crystal filed a case against the Bank of the Philippine Islands (BPI) seeking damages for the foreclosure of properties used as collateral for loans. The trial court ruled in favor of BPI and awarded moral and exemplary damages. The Supreme Court overturned this, finding that while corporations can claim moral damages, BPI did not prove that a single lawsuit caused any besmirching of their reputation. As such, the award of moral damages was deleted.
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0% found this document useful (0 votes)
67 views3 pages

Crystal v. BPI

The heirs of Raymundo and Desamparados Crystal filed a case against the Bank of the Philippine Islands (BPI) seeking damages for the foreclosure of properties used as collateral for loans. The trial court ruled in favor of BPI and awarded moral and exemplary damages. The Supreme Court overturned this, finding that while corporations can claim moral damages, BPI did not prove that a single lawsuit caused any besmirching of their reputation. As such, the award of moral damages was deleted.
Copyright
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We take content rights seriously. If you suspect this is your content, claim it here.
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HERMAN C. CRYSTAL, LAMBERTO C.

CRYSTAL, ANN
GEORGIA C. SOLANTE, and DORIS C. MAGLASANG,
as Heirs of Deceased SPOUSES RAYMUNDO I.
CRYSTAL and DESAMPARADOS C. CRYSTAL,
petitioners, vs. BANK OF THE PHILIPPINE ISLANDS,
respondent.
G.R. No. 172428
November 28, 2008

Doctrine: A corporation may have good reputation which,


if besmirched, may also be a ground for the award of
moral damages provided that there must still be proof of
the existence of the factual basis of the damage and its
causal relation to the defendant’s acts.

Facts:
Spouses Crystal obtained a loan in behalf of Cebu
Contractors Consortium Co. (CCCC) from the Bank of the
Philippine Islands (BPI) Butuan and Cebu branch secured
by chattel mortgage on properties of CCCC and real
estate mortgage over their own property, respectively. The
spouses likewise executed a continuing suretyship where
they bound themselves as surety of CCCC and signed
promissory note which states that they are jointly and
severally liable with CCCC. CCCC failed to pay its loan
when they became due which results to the foreclosure of
the mortgage properties. BPI then filed a complaint for
sum of money against CCCC and the spouses before the
RTC seeking to recover the deficiency of the loan of

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CCCC and the spouses. The spouses filed an action for
Injunction with Damages. The trial court dismissed the
spouses’ complaint and ordered them to pay moral and
exemplary damages and attorney’s fees to BPI. The CA
likewise denied the appeal of the spouses. Hence, this
petition.

Issue:
Whether or not the award for moral damages to BPI is
proper.

Ruling:
No.
Moral damages are meant to compensate the
claimant for any physical suffering, mental anguish, fright,
serious anxiety, besmirched reputation, wounded feelings,
moral shock, social humiliation and similar injuries unjustly
caused. Such damages, to be recoverable, must be the
proximate result of a wrongful act or omission the factual
basis for which is satisfactorily established by the
aggrieved party.
Obviously, an artificial person cannot experience
physical sufferings, mental anguish, fright, serious anxiety,
wounded feelings, moral shock or social humiliation which
are basis of moral damages. A corporation may have good
reputation which, if besmirched, may also be a ground for
the award of moral damages. While the Court may allow
the grant of moral damages to corporations, it is not
automatically granted; there must still be proof of the

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existence of the factual basis of the damage and its causal
relation to the defendant’s acts. This is so because moral
damages, though incapable of pecuniary estimation, are in
the category of an award designed to compensate the
claimant for actual injury suffered and not to impose a
penalty on the wrongdoer.
In the case, BPI may have been inconvenienced by
the suit, but the court do not see how it could have
possibly suffered besmirched reputation on account of the
single suit alone.
Hence, the award of moral damages should be
deleted.

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