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Decision
G.R. No. 227363
ordered as part· of a criminal sentence or as a condition for probation.
Likewise, reparation and indemnification are similarly defined as the
compensation for an injury, wrong, loss, or damage sustained. Clearly, all
of these correspond to actual or compensatory damages defined under the
Civil Code.
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The second type of damages the Court awards are moral damages,
which are also compensatory in nature. Del Mundo v. Court of Appeals
expounded on the nature and purpose of moral damages, viz.:
Moral damages, upon the other hand, may be
awarded to compensate one for manifold injuries such as
physical suffering, mental anguish, serious anxiety,
besmirched reputation, wounded feelings and social
humiliation. These damages must be understood to be in
the concept of grants, not punitive or corrective in nature,
calculated to compensate the claimant for the injury
suffered .. Although incapable of exactness and no proof of
pecuniary loss is necessary in order that moral damages
may be awarded, the amount of indemnity being left to the
discretion of the court, it is imperative, nevertheless, that
(1) injury must have been suffered by the claimant, and (2)
such injury must have sprung from any of the cases
expressed in Article 2219 and Article 2220 of the Civil
Codex xx.
Similarly, in American jurisprudence, moral damages are treated
as "compensatory damages awarded for mental pain and suffering or
mental anguish resulting from a wrong." They may also be considered and
allowed "for resulting pain and suffering, and for humiliation, indignity,
and vexation suffered by the plaintiff as result of his or her assailant's
conduct, as well as the factors of provocation, the reasonableness of the
force used, the attendant humiliating circumstances, the sex of the victim,
[and] mental distress."
The rationale for awarding moral damages has been explained in
Lambert v. Heirs of Rey Castillon: "[T]he award of moral damages is
aimed at a restoration, within the limits possible, of the spiritual status quo
ante; and therefore, it must be proportionate to the suffering inflicted."
Corollarily, moral damages under Article 2220 of the Civil Code
also does not fix the amount of damages that can be awarded. It is
discretionary upon the court, depending on the mental anguish or the
suffering.ofthe private offended party. The amount of moral damages can,
in relation to civil indemnity, be adjusted so long as it does not exceed the
award of civil indemnity.
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Being corrective in nature, exemplary damages, therefore, can be
awarded, not only due to the presence of an aggravating circumstance, but
also where the circumstances of the case show the highly reprehensible or
outrageous conduct of the offender. In much the same way as Article 2230
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