Human Relations

Case Doctrines
15. Velayo vs. Shell Co. Phils., G.R. No. L-7817, October 31, 1956
Every good law draws its breath of life from morals, from those principles which are written with
words of fire in the conscience of man. If this premise is admitted, then the proposed rule is a
prudent earnest of justice in the face of the impossibility of enumerating, one by one, all wrongs
which cause damages. When it is reflected that while codes of law and statutes have changed
from age to age, the conscience of man has remained fixed to its ancient moorings, one can not
but feel that it is safe and salutary to transmute, as far as may be, moral norms into legal rules,
thus imparting to every legal system that enduring quality which ought to be one of its superlative
attributes.
The same observations may be made concerning injurious acts that are contrary to public policy
but are not forbidden by statute. There are countless acts of such character, but have not been
foreseen by the lawmakers. Among these are many business practices that are unfair or
oppressive, and certain acts of landholders and employers affecting their tenants and employees
which contravene the public policy of social justice. *in applying Art. 19
CREDITOR’S LIABILITY IN ASSIGNING ITS CREDIT TO ANOTHER; KNOWLEDGE OF
THE IMPENDING INSOLVENCY PROCEEDINGS OF DEBTOR.—Where a creditor taking
advantage of his knowledge that insolvency proceedings were to be instituted by C if the creditors
did not come to an understanding as to the manner of distribution of the insolvent assets among
them, and believing it most probable that they would not arrive at such understanding as if really
the case schemed and affected the transfer of its credits to its sister corporation in the United
States, where C’s plane C-54 was and by that swift and unsuspected operation efficaciously
disposed of said insolvent’s property depriving the latter and the assignee that was later
appointed, of the opportunity to recover said plane, said creditor acted in bad faith and betrayed
the confidence and trust of the other creditors of the insolvent for which it is held liable in
accordance with pertinent provisions of the Civil Code.
16. Globe Mackay vs. CA, G.R. No. 81262 August 25, 1989
Human Relations; Labor Law; Dismissal; The employer is liable for damages to the employee if
the dismissal is done abusively.—The Court has already ruled that the right of the employer to
dismiss an employee should not be confused with the manner in which the right is exercised and
the effects flowing therefrom. If the dismissal is done abusively, then the employer is liable for
damages to the employee. Under the circumstances of the instant case, the petitioners clearly
failed to exercise in a legitimate manner their right to dismiss Tobias, giving the latter the right to
recover damages under Article 19 in relation to Article 21 of the Civil Code.
The principle of damnum absque injuria does not apply in the instant case considering the abusive
manner in which petitioner exercised its right to dismiss private respondent, and the several other
quasi-delictual acts committed by the former.—According to the principle of damnum absque
injuria, damage or loss which does not constitute a violation of a legal right or amount to a legal
wrong is not actionable [Escano v. CA, G.R. No. L-47207, September 25, 1980, 100 SCRA 197;
See also Gilchrist v. Cuddy, 29 Phil. 542 (1915); The Board of Liquidators v. Kalaw, G.R. No. L-
18805, August 14, 1967, 20 SCRA 987]. This principle finds no application in this case. It bears
repeating that even granting that petitioners might have had the right to dismiss Tobias from
work, the abusive manner in which that right was exercised amounted to a legal wrong for which
petitioners must now be held liable. Moreover, the damage incurred by Tobias was not only in
connection with the abusive manner in which he was dismissed but was also the result of several
other quasi-delictual acts committed by petitioners.
17. Barons Mktg. vs. CA, G.R. No. 126486, 9 February 1998
A person who, in exercising his rights, does not act in an abusive manner is not deemed to have
acted in a manner contrary to morals, good customs or public policy as to violate the provisions
of Article 21 of the Civil Code.
There is undoubtedly an abuse of right when it is exercised for the only purpose of prejudicing or
injuring another. When the objective of the actor is illegitimate, the illicit act cannot be concealed
under the guise of exercising a right. The exercise of a right must be in accordance with the
purpose for which it was established, and must not be excessive or unduly harsh; there must be no
intention to injure another.
18. MWSS v. Act Theater, G.R. No. 147076, June 17, 2004
The exercise of rights is not without limitations; Having the right should not be confused with the
manner by which such right is to be exercised.
When a right is exercised in a manner which discards the norms set in Article 19 of the Civil
Code, resulting in damage to another, a legal wrong is committed for which actor can be held
accountable.
19. Carpio v. Valmonte, G.R. No. 151866, September 09, 2004
To find the existence of an abuse of right, the following elements must be present: (1) there is a
legal right or duty; (2) which is exercised in bad faith; (3) for the sole intent of prejudicing or
injuring another.
A person should be protected only when he acts in the legitimate exercise of his right, that is
when he acts with prudence and good faith; but not when he acts with negligence or abuse.

20. Garcia v. Salvador, G.R. NO. 168512, March 20, 2007

For health care providers, the test of the existence of negligence is—did the health care provider
either fail to do something which a reasonably prudent health care provider would have done, or
that he or she did something that a reasonably prudent health care provider would not have done,
and that failure or action caused injury to the patient.
Where the law imposes upon a person the duty to do something, his omission or non-performance
will render him liable to whoever may be injured thereby.
21. Meralco vs. CA, G.R. No. L-39019, January 22, 1988
The state may regulate the conditions under which and the manner by which a public utility such
as MERALCO may effect a disconnection of service to a delinquent customer. Among others, a
prior written notice to the customer is required before disconnection of the service. Failure to
give such prior notice amounts to a tort.
22. Custodio vs. CA, G.R. No. 116100. February 9, 1996
To warrant the recovery of damages, there must be a right of action for a legal wrong inflicted by
the defendant, and damage resulting to the plaintiff.
Injury is the illegal invasion of a legal right, damage is the harm which results from the injury and
damages are the compensation awarded for the damage suffered.
To maintain an action for injuries, plaintiff must establish that such injuries resulted from a
breach of duty which the defendant owed to the plaintiff.
The law affords no remedy for damages resulting from an act which does not amount to a legal
injury or wrong. In order that the law will give redress for an act causing damage, that act must
not only be hurtful, but also wrongful.
23. Gashem vs. CA, G.R. No. 97336 February 19, 1993
Damages pursuant to Article 21 may be awarded not because of promise to marry but because of
fraud and deceit behind it - Where a man's promise to marry is in fact the proximate cause of the
acceptance of his love by a woman and his representation to fulfill that promise thereafter
becomes the proximate cause of the giving of herself unto him in a sexual congress, proof that he
had, in reality, no intention of marrying her and that the promise was only a subtle scheme or
deceptive device to entice or inveigle her to accept him and to obtain her consent to the sexual
act, could justify the award of damages pursuant to Article 21 not because of such promise to
marry but because of the fraud and deceit behind it and the willful injury to her honor and
reputation which followed thereafter. It is essential, however, that such injury should have been
committed in a manner contrary to morals, good customs or public policy.
24. Rellosa vs. Pellosis, G.R. No. 138964, August 9, 2001
When a right is exercised in a manner which discards these norms resulting in damage to another,
a legal wrong is committed for which the actor can be held accountable; The abuse of rights rule
established in Article 19 of the Civil Code requires every person to act with justice, to give
everyone his due and to observe honesty and good faith. — Petitioner might verily be the owner
of the land, with the right to enjoy and to exclude any person from the enjoyment and disposal
thereof, but the exercise of these rights is not without limitations. The abuse of rights rule
established in Article 19 of the Civil Code requires every person to act with justice, to give
everyone his due; and to observe honesty and good faith. When a right is exercised in a manner
which discards these norms resulting in damage to another, a legal wrong is committed for which
the actor can be held accountable. In this instance, the issue is not so much about the existence of
the right or validity of the order of demolition as the question of whether or not petitioners have
acted in conformity with, and not in disregard of, the standard set by Article 19 of the Civil Code.

25. NPC vs. Philipp Brothers, G.R. No. 126204, 20 November 2001
A person will be protected only when he acts in the legitimate exercise of his right, that is, when
he acts with prudence and in good faith; but not when he acts with negligence or abuse.—Owing
to the discretionary character of the right involved in this case, the propriety of NAPOCOR’s act
should therefore be judged on the basis of the general principles regulating human relations, the
forefront provision of which is Article 19 of the Civil Code which provides that “every person
must, in the exercise of his rights and in the performance of his duties, act with justice, give
everyone his due, and observe honesty and good faith.” Accordingly, a person will be protected
only when he acts in the legitimate exercise of his right, that is, when he acts with prudence and
in good faith; but not when he acts with negligence or abuse.
26. Frenzel vs. Catito, G.R. No. 143958, July 11, 2003
A contract that violates the Constitution and the law, is null and void and vests no rights and
creates no obligations.— Even if, as claimed by the petitioner, the sales in question were entered
into by him as the real vendee, the said transactions are in violation of the Constitution; hence, are
null and void ab initio. A contract that violates the Constitution and the law, is null and void and
vests no rights and creates no obligations. It produces no legal effect at all. The petitioner, being a
party to an illegal contract, cannot come into a court of law and ask to have his illegal objective
carried out. One who loses his money or property by knowingly engaging in a contract or
transaction which involves his own moral turpitude may not maintain an action for his
losses. To him who moves in deliberation and premeditation, the law is unyielding. The law
will not aid either party to an illegal contract or agreement; it leaves the parties where it finds
them.
27. Reyes vs. Lim, G.R. No. 134241, August 11, 2003
Unjust Enrichment; The principle that no person may unjustly enrich himself at the expense of
another is embodied in Article 22 of the Civil Code.—The principle that no person may unjustly
enrich himself at the expense of another is embodied in Article 22 of the Civil Code. This
principle applies not only to substantive rights but also to procedural remedies. One condition for
invoking this principle is that the aggrieved party has no other action based on contract, quasi-
contract, crime, quasidelict or any other provision of law. Courts can extend this condition to the
hiatus in the Rules of Court where the aggrieved party, during the pendency of the case, has no
other recourse based on the provisional remedies of the Rules of Court.
There is unjust enrichment when a person unjustly retains a benefit to the loss of another, or when
a person retains money or property of another against the fundamental principles of justice, equity
and good conscience.
28. NDC vs. Madrigal Wan Hai, G.R. No. 148332, 30 September 2003
The principle of equity has been enshrined in our Civil Code, Article 22.—The case at bar calls to
mind the principle of unjust enrichment—Nemo cum alterius detrimento locupletari potest. No
person shall be allowed to enrich himself unjustly at the expense of others. This principle of
equity has been enshrined in our Civil Code, Article 22 of which provides: “Art. 22. Every person
who through an act or performance by another or by any other means, acquires or comes into
possession of something at the expense of the latter without just or legal ground, shall return the
same to him.” Justice and equity thus oblige that petitioner be held liable for NSCP’s tax
liabilities and reimburse respondent for the amounts it paid. It would be unjust enrichment on the
part of petitioner to be relieved of that obligation.
29. Padilla vs. CA, G.R. No. L-39999 May 31, 1984
Civil liability is not extinguished where acquittal is based on reasonable doubt that accused is
guilty of the crime charged.
The extinction of the civil action by reason of acquittal in the criminal case refers exclusively to
civil liability ex delicto founded on Article 100 of the RPC. Thus, the civil liability is not
extinguished by acquittal where the acquittal is based on reasonable doubt as only preponderance
of evidence is required in civil cases