Here are select August 2012 rulings of the Supreme Court of the Philippines on civil law:
Accion reivindicatoria. Article 434 of the Civil Code provides that in an action to recover, the property must be identified, and the plaintiff must rely on the strength of his title and not on the weakness of the defendant’s claim.
The first requisite is the identity of the land. In an accion reinvindicatoria, the person who claims that he has a better right to the property must first fix the identity of the land he is claiming by describing the location, area and boundaries thereof. Anent the second requisite, i.e., the claimant’s title over the disputed area, the rule is that a party can claim a right of ownership only over the parcel of land that was the object of the deed. It is settled that what really defines a piece of land is not the area mentioned in its description, but the boundaries therein laid down, as enclosing the land and indicating its limits. We have held, however, that in controversial cases where there appears to be an overlapping of boundaries, the actual size of the property gains importance. Leonardo Notarte et al. v. Godofredo Notarte, G.R. No. 180614, August 29, 2012.
Damages; actual and moral damages; factual and legal support required. Article 2199 of the Civil Code is the statutory basis for the award of actual damages, which entitles a person to an adequate compensation only for such pecuniary loss suffered by him as he has duly proved. As such, actual damages if allowed by the RTC, being bereft of factual support, are speculative and whimsical. Without the clear and distinct findings of fact and law, the award amounts only to an ipse dixit on the part of the RTC, and do not attain finality.
Absent a clear and distinct statement of the factual and legal support for the award of moral damages, the award is thus also speculative and whimsical. Moral damages constitute another judicial ipse dixit, the inevitable consequence of which is to render the award of moral damages incapable of attaining finality. In addition, the grant of moral damages in that manner contravenes the law that permit the recovery of moral damages as the means to assuage “physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injury.” Moral damages are not intended to enrich the plaintiff at the expense of the defendant, but to restore the plaintiff to his status quo ante as much as possible. University of the Philippines, et al. v. Hon. Agustin Dizon et al., G.R. No. 171182, Aug. 23, 2012.