Facts: 24th of January 1983 private respondent spouses sent a telegram of

condolence to their cousins through the herein petioner RCPI. The telegram was in
perfect resemblance as to what was intended by the spouses however, it was
written on a birthday card and was sealed in on a Christmasgram envelope.
The spouses contended there was a breach of contract on the part of the RCPI,
they in turn filed complaint on the trial court where it rendered its decision in
favor of the spouses whereas, it was appealed in the CA where also the judgment
in the lower court was affirmed in toto. Thus, the RCPI came to this Court for relief
contending issues that the CA erred in rendering such judgment.
Issue: Whether or not the petitioner committed a breach of contract?
Whether or not the RCPI are held liable for damages?
Held: The Court agrees with the appellate court in its decision and per
endorsement of the trial courts findings that the RCPI as a corporation dealing
with telecommunication are engaged in public interest and therefore rests in their
shoulders an obligation to serve the public with care and without negligence. The
reason of shortage in their production of the appropriate envelope is of no value
to merit for it is their duty to have produced such. The negligence committed is
evidentially sufficient to recover damages because the spouses suffered from
ridicule amongst the people who have come to have knowledge of such activity.

RCPI vs. CA
143 SCRA 657 (1986)
FACTS:

Loreto Dionela alleges that the defamatory words on the telegram sent to him
by the operator RCPI not only wounded his feelings but also caused him undue
embarrassment and affected adversely his business as well because other people have
come to know said defamatory words. RCPI claims, as its defense, that the additional
words in Tagalog were not intended for plaintiff and were included in the original
telegram unintentionally. Dionela filed for damages and was granted by the trial court
and was affirmed by the Court of Appeals the liability of RCPI company employer.
RCPI now comes to the Supreme Court alleging that the CA erred in holding that
RCPI should answer directly and primarily for the civil liability arising from the
criminal action of its employees.
ISSUE:
Is RCPI directly and primarily liable to Dionela for damages?
HELD:
Yes. The action for damages was filed directly against RCPI not as an employer
subsidiarily liable under the provisions of Article 1161 of the New Civil Code in
relation to article 103 of the Revised Penal Code. The cause of action of Dionela is
based on Articles 19 and 20 of the New Civil Code as well as on petitioners breach of
contract thru the negligence of its own employees. As a corporation, the petitioner can
act only through its employees. Hence, the acts of its employees in receiving and
transmitting messages are the acts of RCPI. To hold that RCPI is not liable directly for
the acts of its employees in the pursuit of RCPIs business is to deprive the general
public availing of the services of RCPI of an effective and adequate remedy. In most
cases, negligence must be proved in order that plaintiff may recover. However, since
negligence may be hard to substantiate in some cases, we may apply the doctrine of
RES IPSA LOQUITUR (the thing speaks for itself), by considering the presence of
facts or circumstances surrounding the injury.