Title
Aguila vs. Baldovizo
Case
G.R. No. 163186
Decision Date
Feb 28, 2007
A van sideswiped a pedestrian, leading to his death. Petitioners, including the van's owner and operator, were held solidarily liable for damages. The Supreme Court ruled the original judgment final, voiding an amended decision due to lack of jurisdiction.
pedestrian accident
joint and several liability
damages
A

Case Digest (G.R. No. 162230)

Facts:

  • The Accident and Subsequent Death
    • On April 19, 1993, at about 11:30 a.m., Marlun Lisbos—driving a van (Plate No. TER-883) registered in the name of respondent Danilo D. Reyes—sideswiped Fausto T. Baldovizo as he was crossing EDSA in front of Monumento Market, Caloocan City.
    • Fausto fell onto the pavement, was brought to Manila Central University Hospital, suffered severe injuries, and died on July 6, 1993.
  • Criminal and Civil Proceedings Initiated
    • May 20, 1994: Lisbos was charged with reckless imprudence resulting in homicide before the Metropolitan Trial Court of Caloocan City, Branch 52.
    • September 24, 1994: Fausto’s wife and children filed a separate civil complaint for damages before the RTC of Quezon City, Branch 225, against Marlun Lisbos, Danilo D. Reyes (registered owner), Emerlito F. Aguila (actual operator and possessor), and Times Surety and Insurance Company (insurer).
  • Pleadings and Trial
    • Summons were served on all defendants except Lisbos (whose whereabouts were unknown). In his Answer, Aguila alleged Fausto’s own negligence, due diligence in hiring Lisbos, and that he rendered assistance; Reyes denied ownership, claiming Aguila was the real possessor-operator. The insurer was declared in default.
    • Petitioners failed to appear at the December 1, 1999 hearing and were deemed to have waived their right to present evidence.
  • RTC Decision of March 7, 2000
    • The trial court found all defendants jointly and severally liable, ordering them to pay:
      • ₱43,800.00 (loss of earning capacity)
      • ₱110,700.00 (medical & hospital expenses)
      • ₱15,800.07 (post-confinement medicine expenses)
      • ₱50,000.00 (death indemnity)
      • ₱50,000.00 (moral damages)
      • ₱20,000.00 (exemplary damages)
      • Costs of suit
    • On May 4, 2000, Aguila and Reyes filed a petition for relief from judgment (denied November 20, 2000). The Baldovizos secured a writ of execution; petitioners’ motions to dismiss for lack of jurisdiction and to reconsider were denied.
  • Amended Decision and Appeals
    • August 13, 2001: The RTC struck off Lisbos’s name from the dispositive portion—holding only Aguila, Reyes, and the insurer liable—and issued an Amended Decision.
    • Court of Appeals: Petitioners’ appeal was dismissed as improper—no fresh reglementary period was given by the Amended Decision; original decision had become final and executory.
  • Petition for Review Before the Supreme Court
    • Petitioners contend they retained the right to appeal the Amended Decision and invoke substantial justice to consider their appeal on the merits.
    • The sole issue raised: whether petitioners may appeal the Amended Decision after the original decision had attained finality.

Issues:

  • Main Issue
    • Do petitioners have the right to appeal the August 13, 2001 Amended Decision after the March 7, 2000 Decision had become final and executory?
  • Subsidiary Questions
    • Does an Amended Decision issued after finality revive the reglementary period for appeal?
    • Was the Amended Decision validly issued given the immutability doctrine under Rule 36, Sec. 2 of the Rules of Court?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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