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PRESS BRIEFER – G.R. No. 235737 (Sps. Dorao v. Sps. David)
March 09, 2023
In G.R. No. 235737 (Sps. Melchor and Yolanda Dorao v. Sps. Reynaldo and Nanet David, by themselves and as natural guardians of their minor daughter Ayehza), the respondents David Spouses filed a Petition for Review on Certiorari, seeking to protect their minor daughter’s right to a peaceful life and privacy. They prayed that the Dorao Spouses be held liable for damages for undertaking the wrong approach of, and in assuming the responsibility of, disciplining their daughter.
The Supreme Court Second Division, through Senior Associate Justice Marvic M.V.F. Leonen, ruled against the petitioners Dorao Spouses and found them jointly and severally liable for damages for harassing, intimidating, and spreading false and malicious rumors about the respondents David Spouses and the latter’s daughter.
The Supreme Court affirmed the lower courts’ factual findings that the petitioners were determined in preventing their son and other students from getting closer with the respondent’s minor-daughter and dropped snide remarks at the latter and called her a flirt (“malanding babae”), a woman with loose morals (“puta”), and allegedly sexually aggressive (“makati ang laman”) –within earshot of the minor’s peers, teachers, and parents. These imputations caused the young and impressionable child to feel harassed, intimidated, and exposed to repeated public ridicule and humiliation, adversely affecting her emotional and psychological wellbeing.
Based on the records, petitioners were found to have undoubtedly exposed respondents’ daughter to public ridicule, causing the latter mental anguish, besmirched reputation, wounded feelings, and social humiliation.
Citing the State’s policies and obligation pursuant to the United Nations Convention on the Rights of the Child to defend the rights of children from all forms of abuse, this Court also affirmed the State’s commitment to use a child right-based parenting, caring, and teaching style and to place the child’s best interests in all actions concerning children.
Thus, the Second Division, speaking for the Court, found petitioners’ actions to be violative of respondents’ rights under Article 26 of the Civil Code and to be contrary to morals, good customs, or public policy. Thus, the Supreme Court affirmed the lower courts’ awards of damages and attorney’s fees pursuant to Articles 21 and 26 of the Civil Code. The dispositive portion reads:
ACCORDINGLY, premises considered, the assailed July 11, 2017 Decision and October 26, 2017 Resolution of the Court of Appeals in C.A.-G.R. CV No. 106749 are AFFIRMED WITH
MODIFICATION as to the award of civil indemnity. Melchor and Yolanda Dorao are hereby ordered to pay jointly and severally:
- PHP 30,000.00 as moral damages;
- PHP 20,000.00 as exemplary damages; and
- PHP 30,000.00 as attorney’s fees and litigation expenses.
In addition, legal interest of six percent (6%) per annum on the foregoing amounts is hereby imposed, reckoned from the finality of this Decision until full satisfaction.
SO ORDERED.
The Supreme Court Public Information Office will upload a copy of the Decision once it receives a copy from the Supreme Court Second Division Office of the Clerk of Court.
