Question: “Is a corporation entitled to moral damages?
Case Year
Filipinas Broadcasting
v. Agoo Medical & 2005
Educational Center
Hermana C. Crystal,
et al. v. Bank of the 2008
Philippine Islands
First Lepanto Taisho
Insurance Corp. v. 2012
Chevron
San Fernando Regala
Trading Inc. v. Cargill 2013
Philippines
Case Synthesis Chart
Cause of action for Decision Reason
moral damages
Libel, slander or any
form of defamation
“besmirched reputation” Award of moral that besmirches a
(Item 7, article 2217 of the damages corporation with a
Civil Code) GRANTED good reputation may
be a ground for the
award of moral
damages
A single suit alone
could not damage
“moral damages award in Award of moral BPI’s reputation,
favor of the prevailing damages also, BPI did not
defendant” DELETED suffer “social
humiliation” hence, it
is not entitled to
moral damages
The filing alone of a
civil action should not
be a ground for an
Counterclaim for award of moral
“filing of a civil action” moral damages damages in the
DISMISSED same way that a
clearly unfounded
civil action is not
among the grounds
for moral damages.
Failure to prove by
sufficient evidence
“moral damages arising Award of moral that the offender
from culpa contractual” damages debased and
DELETED besmirched the
Corporations’ good
reputation dissolves
the cause of action for
moral damages.
Is a corporation entitled to moral damages?

No. The general rule is a corporation, which is an artificial person, obviously can’t
experience physical and/or mental sufferings which are basis of moral damages.

In the case of Hermana Crystal v. Bank of the Philippine Islands, G.R. No. 172428,
November 28, 2004, the Supreme Court ruled that, citing People v. Manero, a juridical person is
generally not entitled to moral damages because, unlike a natural person, it cannot experience
physical suffering or such sentiments as wounded feelings, serious anxiety, mental anguish or
moral shock.

In First Lepanto Taisho Insurance Corp. v. Chevron, G.R. No. 177839, January 28, 2012,
the Supreme Court ruled that the filing alone of a civil action should not be a ground for an award
of moral damages in the same way that a clearly unfounded civil action is not among the grounds
for moral damages.

However, to every rule there is an exception. In the case of San Fernando Regala Trading
Inc. v. Cargill Philippines, G.R No. 178008, October 9, 2013, although the award for damages
was deleted, the Supreme Court still ruled that moral damages are not awarded to a corporation
unless it enjoyed good reputation which was debased and besmirched by the offender’s
actuations.

In Filipinas Broadcasting v. Agoo Medical and Educational Center, G.R. No. 141994,
January 17, 2005, the Supreme Court ruled that a corporation with a good reputation, if
besmirched, may also be a ground for the award of moral damages. Moreover, under item (7)
Article 2217 of the Civil Code, moral damages maybe recovered if the action of the offender is
classified as any form of defamation.

The cases above clearly portrayed that the purpose for moral damages is not to impose a
penalty on the wrongdoer but to compensate for the actual injury suffered by the victim. There
must be an actual injury suffered by the corporation in order for it to successfully claim for moral
damages. In other words, moral damages may be awarded only when a juridical person has a
good reputation that is debased resulting in social humiliation. Thus, the award for moral damages
is not always automatically granted.