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​LBC Express vs. CA (236 SCRA 602)

5/12/2024

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 Facts:
Adolfo Carloto, President- Manager of Rural Bank of Labason was instructed to go to Central Bank Main’s office in Manila for the rediscounting obligations of the Rural Bank of Labason. He purchased a round-trip plane ticket to Manila and he asked his sister to send him the rediscounting papers he needed and a pocket money worth 1,000 pesos thru LBC office at Dipolog City. Unfortunately, the documents arrived but he did not received the pocket money he expected. He made follow-ups regarding the money and even went to the LBC office at Dipolog City. However, the money returned to him only after few days and he wasn’t able to go to Manila for the time to settle the rediscounting obligations and consequently a penalty of 32,000 pesos was charged for the delay of settling the rediscounting obligations. According to Carloto he suffered embarrasment and humiliatio of what happened he filed a suit against LBC for moral damages and the reimbursement of 32,000 pesos. Later, Rural Bank of Labason impleaded in the complaint as co-plaintiff and claim for the same relief. LBC, on the other hand, contend that LBC, as a corporation and artificial being can’t recover moral damages.

Issue:
Whether or not Rural Bank of Labason Inc. should be awarded moral damages.

Held:
​No. Moral damages are granted in recompense for physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injury. A corporation, being an artificial person and having existence only in legal contemplation, has no feelings, no emotions, no senses; therefore, it cannot experience physical suffering and mental anguish. Mental suffering can be experienced only by one having a nervous system and it flows from real ills, sorrows, and griefs of life — all of which cannot be suffered by respondent bank as an artificial person.
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