St. Louis Realty Corporation vs. C.A.

GR No L-46061 (November 14, 1984) J AQUINO

Facts: St. Louis Reality Corp. caused to be published on the December 15, 1968 Sunday
Times an advertisement featuring the house of Dr. Conrado J. Aramil. Said advertisement
was entitled Where the Heart is, showed a picture of Dr. Aramils house but with the family
of Arcadio S. Acradio depicted as the owners. It also had written text stating that the
Arcadios had purchased such house in Brookside Hills village at an affordable rate. Such was
done without the permission of Dr. Aramil. Upon seeing a reprint of the advertisement on the
same paper on January 5, 1969, Dr. Aramil immediately wrote said reality corporation stating
that the latter did not obtain permission to post his house in the advertisement and depict it
as being owned by another family. Dr. Aramil explained that it has caused him humiliation as
his colleagues and friends who recognize his house or have been to such have uttered
remarks questioning the ownership of his house, his integrity, if he rented the house from
the Arcadios and even that his wife was that of another husband. He then warned the
corporation that he would pursue legal action if such acts were not explained satisfactorily
to him within one week of receipt of the letter. Said letter was received and answered by
Ernesto Magtoto, an officer of said corporation who was in charge of advertising. He
immediately stopped its publication and contacted Dr. Aramil to apologise. However no
rectification or apology was ever published. Dr. Aramils counsel demanded actual, moral
and exemplary damages of P 110,000 from the corporation on February 20, 1969. The
corporation answered by claiming that it was an honest mistake and that a rectification will
be made. The corporation published a new advertisement on March 18, 1969 which again
portrayed the Arcadio family, but this time with their real house. However no apology or
rectification was included. This led to the filing of a complaint for damages against the said
corporation on March 29, 1969. The lower court and appellate court ruled in favor of Dr.
Aramil; awarding him P 8,000 as actual damages, P 20,000 as moral damages and P 2,000
for attorneys fees.
Issue: W/N case is covered by article 26 of the Civil Code
Held: Yes, the case falls under said article which warrants the award of damages to Dr.
Aramil. Said article provides that "every person shall respect the dignity, personality, privacy
and peace of mind of his neighbors and other persons". "Prying into the privacy of another's
residence" and "meddling with or disturbing the private life or family relations of another"
and "similar acts", "though they may not constitute a criminal offense, shall produce a cause
of action for damages, prevention and other relief". Such article was violated when the
corporation released an advertisement depicting Dr. Armils home to be that of another,
without Dr. Aramils permission. Further, bad faith and negligence was evident as the
corporation refused to publish a rectification or apology despite demands The damages
awarded are proper being enunciated by Articles 2200, 2208 and 2219 of the Civil Code.
Article 2219 allows moral damages for acts mentioned in Article 26.