A person's exercise of a legal right, such as a wife's prerogative in matters concerning her husband, is not absolute and must conform to the standards of conduct prescribed by Article 19 of the Civil Code; exercising such a right in bad faith, with the intent to prejudice or injure another, constitutes an abuse of right that is legally actionable and gives rise to liability for damages under Article 21 of the Civil Code.

The respondents are the children and grandchildren of the late Pascasio S. Banaria from his previous marriage. The petitioner, Adelaida C. Navarro-Banaria, is the legal wife of Pascasio and the stepmother to his children. At the time of the events, Pascasio was elderly, frail, and suffering from physical and mental infirmities that rendered him dependent on others. The dispute arose from the respondents' efforts to celebrate their patriarch's 90th birthday, an annual family tradition, and the petitioner's alleged malicious actions that prevented his attendance and caused the respondents significant distress and financial loss.

• Respondents planned a grand 90th birthday celebration for their father, Pascasio, scheduled for February 22, 2004, starting their preparations a year in advance.
• Between November 2003 and January 2004, respondents were in continuous contact with petitioner Adelaida, who confirmed that she would bring Pascasio to the event.
• Two of the respondents, Reina and Gracia Severa, flew from the United States to the Philippines for the celebration and visited their father on February 14 and 15, 2004, where Adelaida again promised Pascasio would be present.
• On the day of the party, Pascasio and Adelaida did not appear at the venue, where almost 200 guests were waiting.
• Respondents were unable to contact Adelaida, causing them great worry and embarrassment, forcing them to continue the celebration without the guest of honor.
• Worried, the respondents went to a police station to report Pascasio as a missing person and filed an official report the next day when more than 24 hours had passed without contact.
• A maid later informed respondent Paulina that Adelaida and Pascasio had gone to Tarlac on February 21, 2004, but had gone their separate ways there.
• On the evening of February 23, 2004, respondents found Pascasio and Adelaida at their residence in Quezon City.
• When confronted, Adelaida claimed Pascasio did not want to go to the party and, when pressed about her broken promise, she retorted, "I am the wife."

• Petitioner Adelaida argued that she was not privy to the respondents' planned birthday celebration for Pascasio.
• She contended that she did not violate Article 19 of the Civil Code because her actions were not motivated by bad faith, malice, or an intent to injure the respondents.
• She claimed her decision was made to spare her frail husband the embarrassment and humiliation of potentially defecating or urinating uncontrollably in public due to his advanced age.
• She asserted that the case was one of damnum absque injuria (damage without legal injury), as she was merely exercising her legal right as a wife and any harm suffered by respondents was not a result of a violation of a legal duty.

• Respondents argued that Adelaida acted with bad faith, malice, and deliberately failed to honor her repeated promises to bring Pascasio to his 90th birthday party.
• They presented evidence of their continuous communication with Adelaida, who had consistently confirmed Pascasio's attendance.
• They claimed that Adelaida's failure to bring Pascasio to the event and her subsequent unavailability caused them significant financial loss, as well as mental anguish, serious anxiety, social humiliation, and embarrassment in front of their 200 guests.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether the petitioner violated Articles 19 and 21 of the Civil Code on Human Relations by failing to bring her husband to his birthday celebration as promised.
  • Whether the petitioner is liable to the respondents for actual, moral, and exemplary damages, as well as attorney's fees.

• Procedural:
  • N/A
• Substantive:
  • The Supreme Court denied the petition and affirmed the decision of the Court of Appeals.
  • The Court ruled that petitioner Adelaida violated Article 19 of the Civil Code. While she had the right as a wife to decide on matters concerning her husband, this right is not without limits and must be exercised in good faith.
  • Adelaida's failure to inform the respondents of Pascasio's supposed refusal to attend, despite knowing the extensive preparations and having ample opportunity to do so, constituted bad faith and an abuse of her right.
  • The Court found her excuse that Pascasio suddenly decided not to attend to be feeble and unrealistic, and her failure to communicate this demonstrated a lack of good faith.
  • This abuse of right under Article 19 created a cause of action for damages under Article 21 of the Civil Code, as her acts were contrary to good customs and caused injury to the respondents.
  • The Court upheld the CA's award of actual damages for party expenses (food, cake, balloons), moral damages for the humiliation and anxiety suffered, exemplary damages to deter similar wanton acts, and attorney's fees as respondents were constrained to file suit.

• Abuse of Right Principle (Article 19, Civil Code) — This doctrine mandates that every person must, in the exercise of his rights and performance of his duties, act with justice, give everyone his due, and observe honesty and good faith. The Court applied this principle to hold that while the petitioner had a right as a wife, she exercised it in bad faith by intentionally failing to bring her husband to a celebration prepared by his children and by failing to inform them, thereby causing injury.
• Acts Contra Bonus Mores (Article 21, Civil Code) — This article provides that any person who willfully causes loss or injury to another in a manner that is contrary to morals, good customs, or public policy shall compensate the latter for the damage. The Court invoked this to establish that the petitioner's bad faith actions, which violated the standards of good conduct under Article 19, were legally compensable.
• Damnum Absque Injuria — This maxim means "damage without legal injury" and applies when a person sustains harm that does not arise from a violation of a legal right or duty. The Court rejected the petitioner's invocation of this doctrine, finding that the respondents' damages were a direct result of the petitioner's violation of her legal duty to act in good faith under Article 19, thus constituting an actionable injury.

• "All in all, the foregoing shows that Adelaida intentionally failed to bring Pascasio to the birthday celebration prepared by the respondents thus violating Article 19 of the Civil Code on the principle of abuse of right. Her failure to observe good faith in the exercise of her right as the wife of Pascasio caused loss and injury on the part of the respondents, for which they must be compensated by way of damages pursuant to Article 21 of the Civil Code."

• GF EQUITY, Inc. v. Valenzona — Cited to explain the legal concept and correlation between Articles 19, 20, and 21 of the Civil Code, which together form the foundation of the abuse of right principle.
• Metroheights Subdivision Homeowners Association, Inc. v. CMS Construction and Development Corp. — Referenced for the elements of an abuse of right: (1) there is a legal right or duty; (2) which is exercised in bad faith; (3) for the sole intent of prejudicing or injuring another.

• Rule 45 of the Rules of Civil Procedure — This rule provided the legal basis for the petitioner's appeal to the Supreme Court via a petition for review on certiorari.
• Article 19 of the Civil Code — This was the central provision applied by the Court, establishing the standard of conduct (acting with justice, giving everyone his due, and observing honesty and good faith) that the petitioner was found to have violated.
• Article 21 of the Civil Code — This article was applied as the legal basis for awarding damages, as it makes any act contrary to morals or good customs that causes injury to another compensable.

• Justice Alfredo Benjamin S. Caguioa — In his concurring opinion, Justice Caguioa provided a detailed historical and theoretical discussion of the abuse of right principle under Articles 19, 20, and 21. He emphasized that these provisions were designed as a "catch-all" to redress wrongs not covered by specific statutes, ensuring that no one who suffers damage from another's act is left without a remedy. He characterized the petitioner's repeated failure to simply inform the respondents of their absence as gross negligence, which is a thoughtless disregard of consequences, further justifying the award of moral and exemplary damages.