Galang v. Court of Appeals
REITERATIONFacts
The Antecedents: Plaintiff Beatriz Galang filed an action against Rodrigo Quinit and his father, Maximo Quinit, for damages due to an alleged breach of promise to marry by Rodrigo. The Court of First Instance (CFI) awarded actual damages, moral damages, and attorney's fees against both defendants. The Court of Appeals (CA) absolved Maximo Quinit and eliminated the awards for moral damages and attorney's fees against Rodrigo Quinit. Procedural History: The CFI ruled in favor of the plaintiff. The CA reversed the decision regarding Maximo Quinit and modified it regarding Rodrigo Quinit. The case reached the Supreme Court via a petition for certiorari filed by the plaintiff. The Petition: The plaintiff appealed the CA's decision, arguing that the CA erred in the appreciation of evidence and in not awarding moral damages.
Issue(s)
Whether the Court of Appeals erred in the appreciation of evidence. Whether the Court of Appeals erred in not awarding moral damages to the plaintiff.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, without special pronouncement as to costs.
Ratio Decidendi
On the issue of appreciation of evidence: The Court held that the findings of the Court of Appeals on the credibility of the evidence are beyond the power of review on appeal by certiorari and are therefore conclusive upon the Supreme Court. This means that the Supreme Court generally defers to the factual findings of the appellate court, especially concerning the weight and credibility given to testimonial and documentary evidence presented by the parties. The plaintiff's contention that the CA erred in appreciating the evidence was thus dismissed on procedural grounds. On the issue of moral damages for breach of promise to marry: The Court reiterated that moral damages for breach of promise to marry are not collectible under Philippine laws. This issue had already been settled adversely to the plaintiff's contention in the case of Hermosisima vs. Court of Appeals. The Court's adherence to precedent (stare decisis) dictates that unless there is a compelling reason to overturn established jurisprudence, prior rulings on the matter are binding. Therefore, the elimination of moral damages by the Court of Appeals was upheld.
Main Doctrine
Moral damages for breach of promise to marry are not collectible under Philippine law, as settled in previous jurisprudence.