People of the Philippines vs.

Stephen Mark Whisenhunt

Facts:
Whisenhunt and Elsa Santos- Castillo are lovers. They were both married but were both
estranged from they respective spouses. Whisenhunt worked as Manager in Apex Motor
Corporation while Elsa worked as an Assistant Personnel Manager. Elsa resigned from work to
avoid nasty rumors.
One day, Whisenhunt ordered Demetrio Ravelo, his driver, to fetch Elsa from her parents home
and bring her to his condominium in San Juan.
2 days later, while inside the servants quarter, Whisenhunt asked Demetrio how long he wanted
to work for him. Demetrio answered that he was willing to work for the accused forever. The
accused then confided to Demetrio that he had a problem. The accused told Demetrio that Elsa
died of bangungot and asked Demetrio to help him dispose of her body. Demetrio saw Elsas
body already mutilated and dismembered.
They drove to Sta. Rosa, Laguna where they disposed of the dismembered body of Elsa. En
route to the accuseds familys rest house in Bagac, Bataan, they disposed of Elsas things.
Demetrio confessed everything that happened to his wife who then advised him to consult with
Fiscal Joey Diaz.
RTC found accused guilty of murder and sentenced him to suffer the penalty of Reclusion
perpetua and to pay the family of the victim: P100,000.00 representing actual expenses for the
funeral services and wake for 5 days; P3,000,000.00 by way of moral damages; Exemplary
damages in the amount of P1,000,000.00; Attorneys fees in the amount of P150,000.00
Issue: Whether or not the amount of Moral Damages granted to the family of the victim was right.
Held/ Ratio: No. The award of moral damages in murder cases is justified because of the physical
suffering and mental anguish brought about by the felonious acts, and is thus recoverable in
criminal offenses resulting in death. It is true that moral damages are not intended to enrich the
victims heirs or to penalize the convict, but to obviate the spiritual sufferings of the heirs.
Considering, however, the extraordinary circumstances in the case at bar, more particularly the
unusual grief and outrage suffered by her bereaved family as a result of the brutal and
indecent mutilation and disposal of Elsas body, the moral damages to be awarded to them should
be more than the normal amount dictated by jurisprudence. However, the amount of
P3,000,000.00 awarded by the trial court as moral damages is rather excessive. The reasonable
amount is P1,000,000.00 considering the immense sorrow and shock suffered by Elsas heirs.