Rellosa v. Pellosis
REITERATIONFacts
The Antecedents: Respondents were lessees of a parcel of land owned by Marta Reyes, where they had built their houses. After Marta's demise, her son Victor informed respondents of their right of first refusal to buy the land. In 1989, without respondents' knowledge, the land was sold to petitioner Cynthia Ortega, who secured title. On May 25, 1989, Ortega filed a petition for condemnation of the structures with the Office of the Building Official, City of Manila. On May 31, 1989, respondents filed a suit for the Declaration of Nullity of the Sale with the Regional Trial Court (RTC), asserting their right of first refusal was violated. Procedural History: The Office of the Building Official issued a resolution on November 27, 1989, ordering the demolition of respondents' houses. Copies were served on December 7, 1989. On December 8, 1989, petitioners attempted to demolish the houses but were stopped by the police. On December 11, 1989, respondents filed an appeal against the demolition order. On December 12, 1989, petitioners proceeded with the demolition. Respondents filed a complaint with the RTC for damages. The RTC dismissed their complaint and ordered them to pay petitioners moral damages. On appeal, the Court of Appeals (CA) reversed the RTC decision, ordering petitioners to pay respondents moral damages, exemplary damages, and attorney's fees. The Petition: Petitioners filed the instant petition, contending that the CA erred in awarding damages for the premature demolition, arguing that the demolition order was eventually upheld on appeal and the structures were declared dangerous.
Issue(s)
Whether the premature demolition of respondents' houses, prior to the demolition order becoming final and executory, constitutes an abuse of rights entitling respondents to damages. Whether the award of moral and exemplary damages by the Court of Appeals was excessive.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, with modification as to the amount of damages awarded. The Court ruled that the premature demolition constituted an abuse of rights and ordered petitioners to pay respondents moral and exemplary damages, albeit reduced from the CA's award.
Ratio Decidendi
On the issue of premature demolition and abuse of rights: The Court reiterated the principle that the exercise of rights must be done with justice, honesty, and good faith, as enshrined in Article 19 of the Civil Code. While petitioners, as owners of the land, had the right to enjoy and dispose of their property, this right is not absolute and is subject to limitations. The Court found that petitioners abused their rights when they implemented the demolition order on December 8, 1989, and again on December 12, 1989, barely five days after respondents received the demolition order on December 7, 1989. At that time, the demolition order was not yet final and executory, as respondents had a fifteen-day period within which to perfect an administrative appeal. By proceeding with the demolition before the expiration of this appeal period, petitioners effectively deprived respondents of their legal recourse. The subsequent affirmation of the demolition order by the Department of Public Works and Highways did not cure the illegality of the premature action. The Court emphasized that while securing the demolition order was not condemnable, implementing it in disregard of respondents' right to contest the ruling was indefensible. Therefore, the premature demolition constituted a legal wrong for which petitioners could be held accountable. On the excessiveness of damages: The Court found the award of P75,000.00 for exemplary damages and P75,000.00 for moral damages for each respondent to be excessive given the circumstances. Consequently, the Court modified the appellate court's decision by reducing these awards to P20,000.00 for exemplary damages and P20,000.00 for moral damages for each respondent, deeming these amounts to be more reasonable.
Main Doctrine
The exercise of a right, even ownership, is not absolute and must be tempered by the norms of justice, honesty, and good faith. Implementing a demolition order before it becomes final and executory, thereby depriving the aggrieved party of their right to appeal, constitutes an abuse of rights and renders the actor liable for damages.