Short answer. Yes, as between you and that party. Article 2223 says an award of nominal damages precludes further contest upon the right involved and all accessory questions, as between the parties to the suit or their heirs and assigns. The right itself is settled going forward.
What the law says
The adjudication of nominal damages shall preclude further contest upon the right involved and all accessory questions, as between the parties to the suit, or their respective heirs and assigns.
Civil Code, Article 2223 — Nominal Damages Exclude Other Damages. Read the full provision →
Nominal damages settle the underlying right, not just the money
Article 2223 gives an award of nominal damages an effect that goes beyond the modest sum typically involved. It states that "the adjudication of nominal damages shall preclude further contest upon the right involved and all accessory questions, as between the parties to the suit, or their respective heirs and assigns." The court's award does not just compensate you symbolically — it also settles, as between you and the other party, that the right you asserted actually exists and was violated.
"Accessory questions" are closed off too
The preclusive effect is not limited narrowly to the bare existence of the right. The article extends it to "all accessory questions," meaning related issues that were bound up with establishing that right in the litigation. Once nominal damages have been adjudicated, the same parties cannot reopen those closely connected questions in a later proceeding, even if the money involved was small.
This binds the parties and their heirs and assigns, not the whole world
The article specifically limits this preclusive effect to "the parties to the suit, or their respective heirs and assigns." The finality this article creates operates between the people who were actually involved in that lawsuit, and those who later stand in their shoes through inheritance or assignment. It does not automatically bind unrelated third parties who had no part in the original case and no privity with either side.
Why a small award still has this significant effect
Nominal damages are awarded precisely to vindicate a right that was violated, even where no substantial financial loss was proven, so the point of the award is the acknowledgment of the right itself rather than the money. Because that acknowledgment is the whole purpose, it makes sense that the law treats the underlying right as conclusively settled between the parties once nominal damages are awarded — otherwise, the same dispute over that right could be endlessly relitigated between the same people despite already having been judicially resolved.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Seven Brothers Shipping Corporation vs. DMC-Construction Resources, Inc, G.R. No. 193914, November 26, 2014 — read the decision on LawPhil →
- Perla Compania De Seguros, Inc., et al. vs. Sps. Gaudencio Sarangaya III, et al, G.R. No. 147746, October 25, 2005 — read the decision on LawPhil →
- Pnoc Shipping And Transport Corp. vs. Court of Appeals, et al, G.R. No. 107518, October 8, 1998 — read the decision on LawPhil →