Law School Noob: [CASE DIGEST] Samson v. BPI (G.R. No. 150487)

Monday, May 3, 2021

[CASE DIGEST] Samson v. BPI (G.R. No. 150487)

July 10, 2003

FACTS:

Gerardo F. Samson, Jr. deposited a Prudential Bank check worth P3,500.00 to his savings account. Subsequently, he asked his daughter to withdraw P2,000, but the request for withdrawal was denied due to insufficient funds.

Samson had a valued creditor who was waiting at his residence. The creditor was waiting for Samson to pay an obligation that was due at that time. Unable to pay, Samson's credit line was severed. He also suffered humiliation and besmirched reputation.

Following this incident, Samson deposited P5,500.00. Here, he discovered that his balance remained P342.38, and that the earlier deposit of P3,500.00 had not been credited. When he inquired about what happened, BPI confirmed the deposited check but could not account for it.

Upon further investigation, it was found out that their security guard had encashed the check and that, despite knowledge of the irregularity, BPI had not informed Samson. Samson also claimed that while probing the incident, BPI manager Cayanga allegedly displayed arrogance, indifference, and discourtesy towards him, prompting him to file a complaint for damages against BPI.

The trial court rendered a decision in favor of Samson, including an award for moral damages amounting to P200,000. CA affirmed the trial court's ruling but reduced the amount of moral damages to P50,000.00.

ISSUE:

Whether the CA was correct in reducing the amount for moral damages awarded to Samson. -- NO.

HELD:

The award for moral damages should be increased to P100,000.00 because Samson was a businessman and the highest lay person in the United Methodist Church. It was proven that he was regarded with arrogance and a condescending manner, and that BPI had successfully postponed compensating him for more than a decade.

Moral damages are meant to compensate the claimant for any physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation and similar injuries unjustly caused. Moreover, although incapable of pecuniary estimation, the amount must somehow be proportional to and in approximation of the suffering inflicted. Moral damages arenot punitive in nature and were never intended to enrich the claimant at the expense of the defendant.

There is no hard-and-fast rule in determining moral damages; each case must be governed by its own peculiar facts. Trial courts are given discretion in determining the amount, with the limitation that it “should not be palpably and scandalously excessive.”

Moral damages are awarded to restore the spirit quo ante (actual damages compensate tangible damages, moral damages restore the damages in spirit). Compensation is made by uplifting the morale, spirit, mental, and emotional state of the victim.

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