Wednesday, January 13, 2016

MAGBANUA vs. INTERMEDIATE APPELLATE COURT [G.R. Nos. L-66870-72; June 29, 1985]


Facts:

        The plaintiffs filed a petition against the respondents all surenamed Perez alleging that they are shared tenants of the defendants, and that the latter divert the flow of water from their farm lots which caused the drying up of their landholdings and asked to vacate their areas for they could not plant palay due to lack of water. The trial court rendered a decision in favor to the plaintiffs and ordered the defendants to pay moral and exemplary damages to the plaintiffs. The defendants appealed to the IAC which the latter affirmed the appeal by deleting the award of moral and exemplary damages to be awarded to the plaintiffs. Upon the reinstatement of the IAC, the trial court did not agree to the appellate court in its decision because the former believe that as shared tenants, they are entitled to be maintained as agricultural lessees in peaceful cultivation in their respective landholdings.

Issue:

         Whether or not the tenants of defendants were entitled to moral and exemplary damages.

Held:

           The petition is granted and the decision under review is modified and each of the plaintiffs is entitled to receive award of moral and exemplary damages by the defendants.

Ratio:


       Under the law, the landowners have an obligation to keep the tenant in the peaceful and continuous cultivation of his landholding. In this case, it shows that the petitioners were denied irrigation water for their farm lots in order to make them vacate their landholdings. The defendants violated the plaintiff's rights and caused prejudiced to the latter by the diversion of water. Under Article 2219 (10), the Civil Code permits the award of moral damages for acts mentioned in Article 21 of the same Code which provides, Any person who wilfully causes loss or injury to another  in a manner that is contrary to morals, good customs or public policy shall compensate the latter for the damage. The defendants acted in an oppressive manner which is contrary to the morals of the petitioners and therefore, they are liable for the compensation to the latter.

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