**Facts:**
1. **Initial Incident**: On May 16, 1976, during a town fiesta in Pilar, Capiz, Bienvenido Bacalocos, who was intoxicated, hit a bottle on a table injuring his hand. He then approached Rafael Patricio, a local priest and fiesta director, and without provocation, slapped him in the face with his bloodied hand, causing a public commotion.
2. **Criminal Complaint**: Rafael Patricio filed a criminal complaint for slander by deed against Bacalocos in the Municipal Trial Court of Pilar, which was dismissed.
3. **Civil Complaint**: Patricio subsequently lodged a civil complaint for damages against Bacalocos. The Court of First Instance (CFI) of Capiz rendered a decision on April 18, 1978, ordering Bacalocos to pay Patricio P10,000 for moral damages, P1,000 for exemplary damages, and P2,000 for attorney’s fees.
4. **Procedural History**:
– On June 9, 1978, Patricio sought execution of the favorable decision, asserting that it had become final, as Bacalocos had not appealed.
– The CFI denied Patricio’s motion, citing an unresolved motion for reconsideration filed by Bacalocos.
– Bacalocos submitted a supplemental motion without notifying Patricio, which was alleged to be procedurally defective.
– The trial court scheduled and heard oral arguments before dismissing Patricio’s complaint on August 3, 1979, noting the lack of proof for actual damages.
5. **Petition to the Supreme Court**: Patricio filed a petition arguing the motion for reconsideration did not toll the appeal period due to lack of notice and service, asserting entitlement to moral damages without proof of actual damages.
**Issues:**
1. Whether the motion for reconsideration tolled the reglementary period for appeal despite lacking proof of service and notice of hearing.
2. Whether the award for moral and exemplary damages was valid without proving actual or compensatory damages.
3. Whether Bacalocos’ actions, done in a state of inebriation, exempted him from liability for moral damages.
**Court’s Decision:**
1. **Motion for Reconsideration**:
– The Supreme Court found that although service was irregular, Patricio was afforded due opportunity to contest the motion, thereby curing procedural defects. It was emphasized that merits should not be defeated by mere technicalities if parties are heard.
2. **Moral Damages**:
– The Court ruled that moral damages may be awarded without proof of actual damages in cases where the wrongful act results in the complainant’s mental anguish or social humiliation. It upheld Article 2219 of the Civil Code, specifically noting the wrongful act’s impact on Patricio’s reputation and moral dignity.
– Bacalocos’ intoxication and absence of bad faith contention did not absolve him from civil liability for the public slapping, as it was contrary to norms of conduct.
3. **Exemplary Damages**:
– The Court reinstated exemplary damages for educating potential future offenders and as a punitive measure against Bacalocos’ wanton act.
**Doctrine:**
– **Award of Moral Damages**: Under Article 2219 & 2233 of the Civil Code, moral damages can be awarded without proof of compensatory damages if the act is injurious to a person’s mental well-being.
– **Exemplary Damages**: Per Article 2234, these damages can be adjudicated while moral or compensatory damages are awarded, promoting societal deterrence.
**Class Notes:**
1. **Elements of Moral Damage Claim**: Physical or mental suffering, specifically social humiliation or defamation.
2. **Procedural Flexibility**: Courts preferred resolution of cases on merits over strict procedural adherence.
**Historical Background:**
– This case iterates the role of procedural principles where societal values, such as humane and moral treatment, were gravely emphasized during the late-20th century socio-political climate in the Philippines, accentuating civil recourse for dignitary harms amid slanderous acts.
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