327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a plaintiff be allowed to prove the damages claimed from
a breach of contract without prior evidence being submitted in a judgment on
the pleadings?
Case Title: Gloria F. Quiroz vs. Ramon R. Nalus
G.R. No.: 244054
Date of Promulgation: April 26, 2023
Facts of the Case:
This case stems from a contractual dispute between
petitioner Gloria F. Quiroz and respondent Ramon R. Nalus. Quiroz sought
damages for Nalus’s failure to return possession of a property that had been
leased out to a third party, Generika Drugstore, despite his obligation to do
so under the contract.
Quiroz filed for a judgment on the pleadings, where the
trial court awarded her damages. However, the Court of Appeals, in its decision
dated September 20, 2018, reversed the trial court's judgment. The appellate
court deleted the award of damages due to the absence of evidence proving the
actual damages sustained by Quiroz. The appellate court emphasized that moral
damages could not be awarded without factual basis and a causal connection to
the wrongful act. Consequently, the award of exemplary damages was also
unwarranted.
Dissatisfied, Quiroz filed a petition before the Supreme
Court. However, the Supreme Court initially denied the petition, affirming the
appellate court's decision that moral and exemplary damages must be justified
with proper evidence.
Quiroz then filed a motion for reconsideration, citing
previous cases where awards of damages in judgments on the pleadings were
upheld. She argued that since Nalus had not objected to the judgment on the
pleadings, he was deemed to have admitted the allegations in the complaint,
including the damages sought. Alternatively, she prayed that the case be
remanded to the trial court for the presentation of evidence on the damages she
allegedly suffered.
Nalus, on the other hand, contended that damages must be
specifically proven, even if a judgment on the pleadings had been granted. He
asserted that Quiroz had failed to present evidence of her alleged damages.
Primary Issue:
Can Quiroz be allowed to prove the damages she claims to
have suffered arising from Nalus's contractual breach, despite the absence of
prior proof of damages during the judgment on the pleadings?
Supreme Court Decision:
The Supreme Court found Quiroz's motion for reconsideration
meritorious. In its ruling, the Court recognized the necessity of proving
actual damages, even when a judgment on the pleadings is granted. It cited the
case of Swim Phils. Inc. v. CORS Retail Concept Inc., which ruled that
damages must be proven and not merely assumed based on admissions in a judgment
on the pleadings. The Court remanded the case to the Regional Trial Court to
allow Quiroz to present evidence to establish the precise extent of the damages
she had suffered due to Nalus's contractual breach.
The Supreme Court emphasized that, even though Nalus did not
deny his contractual breach, the extent of the damages must be established
through evidence. The earlier cases cited by Quiroz were deemed inapplicable,
as they involved stipulations or admissions on the amount of damages, which was
not the case here.
Dispositive Portion:
The Supreme Court partially granted Quiroz's motion for
reconsideration, modified its earlier resolution, and ordered the remand of the
case to the Regional Trial Court for the reception of evidence on the exact
damages sustained by Quiroz due to Nalus’s breach of contract.
SO ORDERED.
In cases involving judgments on the pleadings, should a
party be required to submit additional evidence to prove damages, or should the
court consider the damages admitted once the judgment is uncontested?
Important Doctrines:
- Actual
Damages Must Be Proven:
- Even
if the allegations regarding the breach of contract are admitted in a
judgment on the pleadings, the extent of actual damages must still be
proven by evidence. A court cannot rely on speculation or conjecture
regarding the amount of damages.
- Judgment
on the Pleadings and Unliquidated Damages:
- Section
11 of the Rules of Court provides that material allegations in the
complaint, except for the amount of unliquidated damages, are deemed
admitted if not specifically denied. However, unliquidated damages must
still be substantiated by evidence.
This case falls under Civil Law.
🎓 Welcome, future
lawyers and bar takers! In this content, we will break down the important jurisprudence
in the Supreme Court case of Gloria F. Quiroz vs. Ramon R. Nalus, G.R.
No. 244054, promulgated on April 26, 2023. This case falls under Civil
Law and deals with the necessity of proving damages in a breach of
contract, even when the facts of the breach are admitted by the defendant.
This discussion is designed to help law students, bar
examinees, and legal professionals recall and understand the doctrinal
value of this case.
📌 Brief Summary:
Quiroz sued Nalus for failing to return her property. The
trial court granted damages without evidence. The Court of Appeals reversed,
and the Supreme Court eventually remanded the case to allow proof of damages,
stating that actual damages must be proven even if the breach is admitted.
💡 If breach is admitted
and the damage is obvious, should courts still require detailed proof of
damages? Comment your insights below!
📚 10 IMPORTANT DOCTRINES
FROM THE CASE (from G.R. No. 244054, April 26, 2023)
- Actual
Damages Must Be Proven
Even when liability is admitted, damages cannot be awarded without evidence. Courts must rely on actual proof, not speculation.
📖 Source: Supreme Court Decision, referencing Raagas v. Traya - Judgment
on the Pleadings Does Not Automatically Admit Damages
Only material averments other than unliquidated damages are deemed admitted. Proof is still necessary for the latter.
📖 Source: Sec. 11, Rules of Civil Procedure - Award
of Moral Damages Requires Factual Basis
A court cannot grant moral damages without a clear causal link to the wrongful act.
📖 Source: p.1 of the attached case decision - No
Exemplary Damages Without Moral Damages
Where moral damages are not awarded, exemplary damages are likewise unwarranted.
📖 Source: Supreme Court’s March 11, 2020 Resolution - Failure
to Deny Damages Does Not Mean Admission
Even if not specifically denied, claims for unliquidated damages are not automatically admitted.
📖 Source: Raagas v. Traya, cited in the decision - Swim
Phils. Ruling Applied
In actions for damages, judgment on the pleadings is improper without evidence on the extent of damage.
📖 Source: Swim Phils. Inc. v. CORS Retail Concept Inc. - Substantial
Justice over Procedural Convenience
The Court prioritized justice by remanding the case for evidence rather than dismissing outright.
📖 Source: Final SC ruling in Quiroz v. Nalus - Distinction
from Santiago and Tropical Homes Cases
In prior cases cited by Quiroz, damages were stipulated or agreed upon—unlike in the present case.
📖 Source: p.3 of attached decision - Court
Cannot Guess the Value of Losses
The Court emphasized that damages require exact valuation and cannot be based on estimates or assumptions.
📖 Source: Raagas v. Traya Doctrine - Remand
is the Remedy When Damages Are Unproven
Instead of denying the claim, the case was sent back to the RTC for proper reception of evidence.
📖 Source: Supreme Court’s dispositive portion
❓ Frequently Asked Questions
(FAQs)
1. What is the core issue in Quiroz v. Nalus?
👉 Whether damages can be
awarded without proof when a defendant admits breach in a judgment on the
pleadings.
2. What happens if damages are unproven?
👉 The Supreme Court ruled
they cannot be awarded. Proof is necessary, especially for unliquidated
damages.
3. Are all admissions in a judgment on the pleadings
binding?
👉 No. Admissions apply
only to material averments, not to the value of unliquidated damages.
4. Can moral and exemplary damages be awarded
automatically in breach cases?
👉 No. They require
specific proof and justification.
5. What did the Supreme Court ultimately do?
👉 It remanded the
case to the trial court to receive evidence on damages.
📌 Case Title: Gloria
F. Quiroz vs. Ramon R. Nalus
📌 G.R. No.: 244054
📌 Date of
Promulgation: April 26, 2023
📚 Classification:
Civil Law
📢 DISCLAIMER: This
is an educational video made using premium AI tools. While efforts were made to
ensure accuracy, we do not guarantee the infallibility of the content. Always
consult the full text of the case and your legal references.
🎓 Welcome to today's
quizzer, law students and future bar topnotchers! This quiz is based on the
Supreme Court case of Gloria F. Quiroz vs. Ramon R. Nalus, G.R. No.
244054, promulgated on April 26, 2023.
This case falls under Civil Law, specifically on the proof
of damages in a breach of contract. It tackles whether a party may be
awarded damages without evidence when the opposing party has admitted breach in
a judgment on the pleadings.
Briefly, the trial court awarded damages without requiring
evidence. The Court of Appeals reversed the award, citing lack of factual
basis. The Supreme Court ruled that actual damages must be proven, and remanded
the case to the trial court for reception of evidence.
📌 Answer key will be
provided at the end of this video. Let’s test your comprehension!
🧠 10 HOTS Multiple Choice
Questions (Easy Difficulty)
1. What was the main legal issue in the case of
Quiroz vs. Nalus?
A. Ownership of land
B. Whether damages can be awarded without proof
C. Jurisdiction of the court
D. Validity of a lease contract
2. What type of damages did the trial court initially
award to Gloria Quiroz without requiring proof?
A. Nominal and temperate damages
B. Liquidated damages
C. Moral and exemplary damages
D. Criminal penalties
3. Why did the Court of Appeals delete the trial
court’s award of damages?
A. There was no breach proven
B. The complaint was dismissed
C. There was no jurisdiction
D. There was no proof of damages
4. What did the Supreme Court ultimately do with the
case?
A. Affirmed the trial court in full
B. Ordered a retrial on liability
C. Remanded the case for reception of evidence
D. Reversed and dismissed the complaint
5. What important legal principle did the Supreme
Court emphasize in its ruling?
A. Proof is not necessary in uncontested cases
B. Admissions include damages
C. Damages must be proven even if breach is admitted
D. Legal costs always include damages
6. In the Supreme Court’s view, what cannot be used
to estimate damages?
A. Witness testimony
B. Stipulated facts
C. Speculation or guesswork
D. Judicial notice
7. Which of the following was not a reason the
Supreme Court denied Quiroz’s direct award of damages?
A. The absence of a stipulated value
B. Nalus denied the breach
C. No admission of the extent of damages
D. Lack of factual evidence
8. What procedural remedy did the Court apply to
balance justice and procedure?
A. Dismiss the case
B. Decide on affidavits alone
C. Remand for trial on damages
D. Rule in favor of the defendant automatically
9. Which prior case did the Supreme Court cite to
explain the need for evidence on damages?
A. Santiago v. Basifan
B. Tropical Homes v. CA
C. Swim Phils. Inc. v. CORS Retail
D. Republic v. Sandiganbayan
10. What is required for the grant of moral damages
according to the Court?
A. Mere allegation of emotional distress
B. No need for evidence if breach is admitted
C. Clear factual basis and causal connection
D. Filing of a counterclaim
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