When does a legal right exercised by a person become an actionable wrong? Is a reneged promise to bring a spouse to a birthday celebration planned by relatives an actionable wrong?
In the case of Navarro-Banaria v. Banaria (G.R. No. 217806, 28 July 2020), respondents were the relatives of the late Pascasio while petitioner Adelaida was the legal wife of Pascasio. Pascasio was frail and suffering from physical and mental infirmities.
The relatives planned a birthday celebration for the 90th birthday of Pascasio as early as a year before. Adelaida promised respondents that Pascasio would be present for the celebration.
Pascasio was, however, nowhere to be found during the 90th birthday celebration. Several attempts were made by respondents to learn Pascasio’s whereabouts. In the end, Pascasio was at home and Adelaida was asked by the respondents why she did not bring Pascasio to the celebration, to which Adelaida replied, “I am the wife.”
A complaint for damages was then filed by the respondents against Adelaida before the Regional Trial Court of Quezon City which ordered Adelaida to pay damages to the respondents. Adelaida elevated the case to the Court of Appeals which affirmed with modification the Regional Trial Court’s decision. Thus, Adelaida sought recourse before the Supreme Court.
In resolving whether Adelaida violated Articles 19 and 21 of the Civil Code regarding Human Relations, the Supreme Court ruled in the affirmative.
Commonly known as the abuse of rights principle, the Supreme Court clarified that Article 19 of the Civil Code sets certain standards that must be observed not only in the exercise of one’s rights but also in the performance of one’s duties. These standards are the following: to act with justice; to give everyone his due; and to observe honesty and good faith.
The Court explained that a right, though by itself legal because recognized or granted by law as such, may nevertheless become the source of some illegality. When a right is exercised in a manner that does not conform to the norms enshrined in Article 19 and results in damage to another, a legal wrong is thereby committed for which the wrongdoer must be held responsible.
The Court laid out the elements of an abuse of rights which are: (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.
Applying the foregoing, the Court found that Adelaida, as legal wife and guardian of Pascasio, had the principal and overriding decision when it came to the affairs of her husband. However, it must be noted that Adelaida’s right cannot be exercised without limitation. The exercise of such right must conform to standards of conduct set out in Article 19 of the Civil Code.
Thus, it was found that Adelaida intentionally failed to bring Pascasio to the birthday celebration prepared by the respondents. Adelaida failed to observe good faith in the exercise of her right as the wife of Pascasio, thus causing loss and injury on the part of the respondents, for which they must be compensated by way of damages pursuant to Article 21 of the Civil Code.
Article 21 reads that any person who willfully 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 Supreme Court basically instructed that the legal exercise of a right may be the subject of an actionable wrong when it was not exercised in good faith or contrary to human relations.