Custodio v. Court of Appeals

G.R. No. 116100 (February 9, 1996)

Facts:

The case originated from a civil suit filed on August 26, 1982, by Pacifico Mabasa against Cristino and Brigida Custodio, Lito and Maria Cristina Santos, and Rosalina Morato in the Regional Trial Court of Pasig, seeking the grant of an easement of right of way. Mabasa owned a parcel of land in Taguig, Metro Manila, which was surrounded by properties owned by the defendants. The only access to Mabasa's property from P. Burgos Street was through two narrow passageways, one of which had been obstructed by the defendants constructing adobe fences.

Mabasa purchased the property in September 1981, which had tenants at the time. However, after the construction of the fences by the defendants, the remaining tenants vacated the premises. The defendants claimed that the construction was necessary due to incidents involving the tenants, including disturbances and safety concerns.

After Mabasa's death, his heirs continued the case, and on February 27, 1990, the trial court ruled in favor of the heirs, granting them a permanent right of way and ordering the defendants to pay P8,000 as indemnity for the use of the passageway. The defendants did not appeal this part of the decision.

Dissatisfied with the trial court's ruling, the heirs of Mabasa appealed to the Court of Appeals, seeking additional damages. On November 10, 1993, the Court of Appeals modified the trial court's decision, awarding the heirs P65,000 as actual damages, P30,000 as moral damages, and P10,000 as exemplary damages. The defendants then sought a review from the Supreme Court.

Legal Issues:

1. Whether the grant of a right of way to the heirs of Mabasa was proper.
2. Whether the award of damages by the Court of Appeals was justified.

Arguments:

• Petitioners (Defendants): The petitioners argued that the trial court's decision granting the right of way was not appealed, thus they were presumed satisfied with that ruling. They contended that the award of damages was erroneous, as it lacked a substantial legal basis. They maintained that the construction of the fence was a lawful exercise of their property rights and did not constitute a legal injury to the heirs of Mabasa.

• Respondents (Heirs of Mabasa): The respondents contended that the trial court erred in not awarding them damages for the losses incurred due to the obstruction of the passageway, which they argued was a violation of their rights. They claimed that the defendants' actions constituted an abuse of rights, justifying the award of damages.

Court's Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals and reinstated the trial court's judgment. The Court held that the petitioners were barred from contesting the propriety of the right of way since they did not appeal the trial court's decision. The Court emphasized that the finality of the trial court's judgment precluded the petitioners from seeking any affirmative relief regarding the right of way.

Regarding the award of damages, the Court found that the Court of Appeals erred in granting damages to the heirs of Mabasa. The Court explained that damages can only be awarded when there is a legal injury resulting from a breach of duty by the defendant. In this case, while the heirs suffered losses due to the tenants vacating the premises, there was no legal injury caused by the petitioners' actions. The construction of the fence was a lawful exercise of the petitioners' property rights, and any resulting damage to the heirs was classified as "damnum absque injuria," meaning damage without legal injury.

The Court reiterated that the law does not provide a remedy for damages resulting from acts that do not constitute a legal wrong. The petitioners' actions in enclosing their property were lawful, and thus, the heirs had no cause of action for damages.

Significant Legal Principles Established:

1. The principle of "damnum absque injuria" applies when a party suffers damage without a corresponding legal injury or wrong.
2. A party who does not appeal a decision cannot seek affirmative relief beyond what was granted in the lower court's ruling.
3. The lawful exercise of property rights cannot constitute a legal wrong, even if it results in incidental damage to another party.