G.R. No. 175822 ; October 23, 2013
CALIFORNIA CLOTHING INC. and MICHELLE S. YBAÑEZ, Petitioners, vs. SHIRLEY G. QUIÑONES, Respondent.

FACTS

Respondent Shirley Quiñones purchased black jeans from petitioners’ Guess USA Boutique. She received an official receipt and left the store. Shortly after, store employees, believing she had not paid, approached her. At her suggestion, they discussed the matter at her workplace, the Cebu Pacific Office, in the presence of clients. The employees later sent a letter to Cebu Pacific’s director narrating the incident, which the employer refused to accept. A similar letter was allegedly furnished to the mall’s HRD. Quiñones filed a complaint for damages, claiming the incident caused her anxiety, humiliation, and a besmirched reputation.
The Regional Trial Court dismissed the complaint, finding the employees acted in good faith based on an honest mistake. The Court of Appeals reversed, holding that while the initial confrontation was in good faith, the act of sending a demand letter to Quiñones’s employer constituted bad faith, warranting an award of moral damages and attorney’s fees.

ISSUE

Whether the Court of Appeals erred in finding petitioners liable for damages based on bad faith.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The legal logic centers on the distinction between good faith in the initial act and bad faith in subsequent conduct. While the employees’ honest belief that payment was missed justified the initial confrontation, their subsequent act of sending a formal letter to Quiñones’s employer constituted actionable wrong. The Court emphasized that bad faith imports a dishonest purpose or moral obliquity; it is a breach of a known duty through some motive or interest or ill will. Here, the sending of the letter to her employer, despite her possession of the receipt and the jeans, was an unnecessary step that went beyond a simple clarification. This act was calculated to expose her to her employer, threatening her professional standing and causing moral injury. The law on human relations under Article 19 of the Civil Code requires every person to act with justice, give everyone their due, and observe honesty and good faith. Petitioners’ act of involving her employer violated this principle. Consequently, the award of moral damages was proper as Quiñones suffered mental anguish, fright, and serious anxiety. Attorney’s fees were also justified as she was compelled to litigate. The amounts awarded were deemed reasonable.