Here are select December 2012 rulings of the Supreme Court of the Philippines on civil law:
Damages; When Applicable. It is essential that for damages to be awarded, a claimant must satisfactorily prove during the trial that they have a factual basis, and that the defendant’s acts have a causal connection to them. Article 2229 of the Civil Code provides that exemplary damages may be imposed “by way of example or correction for the public good, in addition to the moral, temperate, liquidated or compensatory damages.” They are, however, not recoverable as a matter of right. They are awarded only if the guilty party acted in a wanton, fraudulent, reckless, oppressive or malevolent manner. Albert M. Ching, et al. vs. Felix M. Bantolo, et al.; G.R. No. 177086. December 5, 2012
Sale of Real Property; Must be in a Public Document; requirement only for convenience. Article 1358 of the Civil Code provides that acts and contracts which have for their object the transmission of real rights over immovable property or the sale of real property must appear in a public document. If the law requires a document or other special form, the contracting parties may compel each other to observe that form, once the contract has been perfected. In Fule v. Court of Appeals, the Court held that Article 1358 of the Civil Code, which requires the embodiment of certain contracts in a public instrument, is only for convenience, and registration of the instrument only adversely affects third parties. Formal requirements are, therefore, for the benefit of third parties. Non-compliance therewith does not adversely affect the validity of the contract nor the contractual rights and obligations of the parties thereunder. Lagrimas de Jesus Zamora v. Spouses Beatriz Zamora et al., G.R. No. 162930. December 5, 2012.