4/10/2020
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Findings of fact of the CA, when they affirm those of the trial court, are binding on this
Court, unless the findings of the trial and the appellate courts are palpably unsupported
by the evidence on record, or unless the judgment itself is based on a misapprehension
of facts.[12]
Likewise, we have time and again ruled that mere denial cannot prevail over the
positive testimony of a witness. A mere denial, just like an alibi, is a self-serving
negative evidence, which cannot be accorded greater evidentiary weight than the
declarations of credible witnesses who testify on affirmative matters. As between a
categorical testimony that has the ring of truth on the one hand and a bare denial on
the other, the former is generally held to prevail.[13]
We, however, find it proper to modify the amount of moral and exemplary damages
awarded by the CA.
On 12 May 2003, Congress passed R.A. 9208 or the Anti-Trafficking in Persons Act. This
law was approved on 26 May 2003. Ironically, only a few days after, private
complainants found themselves in a situation that this law had sought to prevent.
In Lalli, we increased the amount of moral and exemplary damages from P50,000 to
P500,000 and from P50,000 to P100,000, respectively, having convicted the accused
therein of the crime of trafficking in persons. In so doing, we said:
The Civil Code describes moral damages in Article 2217:
Art. 2217. Moral damages include physical suffering, mental
anguish, fright, serious anxiety, besmirched reputation, wounded
feelings, moral shock, social humiliation, and similar injury.
Though incapable of pecuniary computation, moral damages may
be recovered if they are the proximate result of the defendant's
wrongful act for omission.
Exemplary damages, on the other hand, are awarded in addition
to the payment of moral damages, by way of example or
correction for the public good, as stated in the Civil Code:
Art. 2229. Exemplary or corrective damages are imposed, by way
of example or correction for the public good, in addition to the
moral, temperate, liquidated or compensatory damages.
Art. 2230. In criminal offenses, exemplary damages as a part of
the civil liability may be imposed when the crime was committed
with one or more aggravating circumstances. Such damages are
separate and distinct from fines and shall be paid to the offended
party.
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