2/7/25, 2:16 PM Case Digest: G.R. No. 235737 - Spouses Dorao vs.

G.R. No. 235737 - Spouses Dorao vs. Spouses BBB and CCC 2/7/25, 2:16 PM Case Digest: G.R. No. 235737 - Spouses Dorao vs. Spouses BBB and CCC

The primary issue is whether the Dorao Spouses violated the rights of AAA and her
Title parents to dignity, personality, privacy, and peace of mind, making them liable for
Spouses Dorao vs. Spouses BBB and CCC moral and exemplary damages under Articles 21 and 26 of the Civil Code.

Case Decision Date Ruling:

G.R. No. 235737 Apr 26, 2023
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The
Dorao Spouses were found jointly and severally liable for damages. The Court
Spouses Dorao publicly harassed minor AAA, causing emotional distress and ordered them to pay:
suicide attempt. Court held them liable for damages under Civil Code Articles 21
and 26, affirming lower courts' rulings. 1. PHP 30,000.00 as moral damages to AAA;
2. PHP 20,000.00 as exemplary damages;
Jur.ph - Case Digest (G.R. No. 235737) 3. PHP 30,000.00 as attorney’s fees and litigation expenses;
Legal Reasoning Model 4. Legal interest of 6% per annum from the finality of the decision until full
Facts: payment.

Background of the Case: Ratio:

The case involves Spouses Melchor and Yolanda Dorao (petitioners) and Spouses BBB
and CCC (respondents), the parents of AAA, a minor. The Dorao Spouses are the 1. Violation of Rights Under the Civil Code:
parents of Paul, AAA’s then-boyfriend. The Dorao Spouses’ actions violated Articles 21 and 26 of the Civil Code, which
protect individuals from willful acts causing loss or injury in a manner contrary
The Incident:
to morals, good customs, or public policy, and ensure respect for dignity,
Between July and November 2004, the Dorao Spouses repeatedly harassed and
personality, privacy, and peace of mind.
publicly humiliated AAA due to her relationship with Paul. Yolanda called AAA
derogatory names such as "malanding babae" (flirt) and "makati ang laman" (sexually 2. Best Interest of the Child:
aggressive) in front of her classmates and schoolmates. Yolanda also texted CCC, The Court emphasized that the best interest of a child cannot justify cruel or
calling AAA and her mother "puta" (prostitutes). degrading punishment. The Dorao Spouses’ actions, which included public
humiliation and defamation, demeaned AAA’s intrinsic worth and dignity as a
The Escalation:
human being.
During a parents' meeting at AAA’s school, the Dorao Spouses spread false rumors
about AAA, accusing her of inappropriate behavior with other boys, including 3. Parental Authority Limits:
dragging Paul to a restroom. These actions caused AAA severe emotional distress, While parents have the right to discipline their children, the Dorao Spouses had
leading to depression, a decline in academic performance, and an attempted suicide no authority over AAA. Their actions exceeded the bounds of reasonable parental
by drug overdose. AAA eventually transferred schools to escape the harassment. discipline and were contrary to public policy.
Legal Action: 4. Damages Awarded:
Spouses BBB and CCC filed a case against the Dorao Spouses for violating their Moral damages were awarded to compensate AAA for the mental anguish,
family’s right to privacy and peace of mind, seeking moral and exemplary damages. besmirched reputation, and social humiliation she suffered. Exemplary damages
were imposed to serve as a deterrent against similar behavior in the future.
Issue:
5. Finality of Lower Court Decisions:
The Supreme Court upheld the factual findings of the lower courts, emphasizing
https://jur.ph/jurisprudence/digest/spouses-dorao-v-spouses-bbb-and-ccc 1/3 https://jur.ph/jurisprudence/digest/spouses-dorao-v-spouses-bbb-and-ccc 2/3
2/7/25, 2:16 PM Case Digest: G.R. No. 235737 - Spouses Dorao vs. Spouses BBB and CCC

that its role under Rule 45 is limited to reviewing errors of law, not re-examining
factual issues.

https://jur.ph/jurisprudence/digest/spouses-dorao-v-spouses-bbb-and-ccc 3/3