Philippine Commercial International Bank v. Alejandro
REITERATIONFacts
The Antecedents: Respondent Joseph Anthony M. Alejandro filed a motion for reconsideration seeking an increase in the damages awarded in his favor in a previous decision. He argued for an increase in nominal damages from P50,000.00 to P2 Million, based on the preliminary attachment bond posted by petitioner Philippine Commercial International Bank (PCIB). He also sought an increase in moral damages from P500,000.00 to P5 Million, citing his social and professional standing and alleged untold humiliation. Furthermore, he requested an increase in attorney's fees from P200,000.00 to P1 Million, considering the case's nature and his counsel's standing. Lastly, he sought an increase in exemplary damages from P500,000.00 to P500,000.00 to deter PCIB from securing baseless writs of attachment. Procedural History: The case reached the Supreme Court on a motion for reconsideration of a previous decision that awarded damages to the respondent. The Petition: The respondent prayed for an increase in the amounts of nominal damages, moral damages, attorney's fees, and exemplary damages previously awarded by the Court.
Issue(s)
Whether the award of nominal damages should be increased. Whether the award of moral damages should be increased. Whether the award of attorney's fees should be increased. Whether the award of exemplary damages should be increased.
Ruling
The Court denied the respondent's motion for partial reconsideration with finality.
Ratio Decidendi
On the award of nominal damages: The Court held that the award of P50,000.00 as nominal damages was proper. Nominal damages are intended to vindicate the violation of a right, not to indemnify for loss. The duration of the period the respondent was prevented from exercising his right (two months) was deemed the most appropriate yardstick. The amount of the bond posted did not prove actual sum garnished, and the P2 Million claim was considered excessive and without basis. On the award of moral damages: The Court found the P500,000.00 award for moral damages to be commensurate to the anxiety and inconvenience suffered by the respondent. The claim for P5 Million was deemed scandalously excessive. The respondent failed to present any witness to corroborate his self-serving allegations of untold humiliation and disclosure to clients, thus failing to prove by preponderance of evidence the degree of moral suffering. Competent and substantial proof of suffering is essential for such an award. On the award of attorney's fees: The Court ruled that the professional standing of a counsel must be established during trial proper, where the opposing party can raise objections and cross-examine. It was too late to present such evidence at the motion for reconsideration stage. Moreover, the issue of the propriety of garnishment was considered simple and did not warrant an award of P1 Million in attorney's fees. On the award of exemplary damages: The Court affirmed the P500,000.00 award for exemplary damages as reasonable and sufficient to discourage the petitioner from resorting to unfounded assertions in securing writs of attachment. Exemplary damages are meant to serve as a deterrent against socially deleterious actions, not to enrich one party or impoverish another.
Main Doctrine
The award of damages, including nominal, moral, and exemplary damages, as well as attorney's fees, must be supported by competent and substantial proof of the injury or loss suffered, and the amounts claimed must be reasonable and commensurate to the actual damages or the purpose for which they are awarded. The professional standing of counsel, if to be considered for attorney's fees, must be established during trial proper.