Title
Amihan Bus Lines, Inc. vs. Romars International Gases Corp.
Case
G.R. No. 180819
Decision Date
Jul 5, 2010
A bus collided with a gas tanker, causing damages. Petitioner claimed extrinsic fraud due to counsel's negligence, but the Supreme Court ruled against it, citing lack of due diligence and no evidence of fraud.

Case Digest (G.R. No. 180819)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties Involved
    • The case involves Amihan Bus Lines, Inc. (petitioner) and Romars International Gases Corporation (respondent), represented by Charlie J. Sapugay.
    • The dispute arose from a vehicular collision involving a gas tanker owned by Romars and a bus operated by Amihan.
  • Collision Incident
    • On February 20, 2005, at approximately 2:00 p.m., an almost head-on collision occurred along Quirino Highway in Ragay, Camarines Sur.
    • The incident involved Romars’ gas tanker (tractor number TCC 583, trailer number UUP 138) and Amihan’s bus (plate number DVG 844).
    • The gas tanker was negotiating an inclined curve when it was struck by the oncoming bus that suddenly veered into its lane, resulting in damages to both vehicles and a total wreck of the trailer.
  • Pre-Trial and Filing Proceedings
    • On July 22, 2005, Romars filed a complaint in RTC, seeking:
      • Actual damages of ₱800,000.00 for the replacement of the tractor head and ₱50,000.00 per month for unrealized net income.
      • Exemplary damages amounting to ₱50,000.00.
      • Attorney’s fees of ₱50,000.00.
    • Amihan Bus Lines filed its Answer with Compulsory Counterclaims alleging:
      • It exercised the required diligence in supervising its employees.
      • The complaint was dismissed for lack of cause of action.
      • It claimed damages of ₱47,055.00 for bus repair, ₱210,000.00 for unrealized profits, ₱50,000.00 for exemplary damages, and ₱50,000.00 for attorney’s fees.
  • Pre-Trial Conferences and Evidence Presentation
    • A preliminary conference was held on January 27, 2006, where plaintiff’s counsel submitted its pre-trial brief.
    • Subsequent scheduling adjustments:
      • A continuation was set on February 20, 2006, due to the absence of defendant’s counsel.
      • Pre-trial was initially set for March 20, 2006, where only the plaintiff’s counsel appeared; a representative of Amihan indicated willingness for an amicable settlement, prompting rescheduling to March 29, 2006.
    • Continued procedural issues:
      • On March 29, 2006, only the plaintiff’s counsel was present, leading the court to allow the plaintiff to present its evidence ex-parte on May 16, 2006.
      • The defendant later appeared with new counsel, requesting a resetting, which was granted with a new preliminary conference on July 3, 2006 and pre-trial on July 10, 2006.
      • Pre-trial was again reset to August 31, 2006, but defendant’s counsel did not appear, leading to the court granting plaintiff’s prayer for ex-parte presentation of evidence on October 11, 2006.
    • On December 14, 2006, defendant filed an “Entry of Appearance with Motion to Allow Defendant to Present its Evidence,” alleging non-appearance due to counsel withdrawal; the trial court denied this motion as the excuse was found unsatisfactory.
  • Trial, Judgment, and Execution
    • On April 17, 2007, the RTC rendered judgment in favor of Romars, attributing liability to the bus driver who, by attempting to overtake a parked trailer on a curved lane, collided with the oncoming tractor.
    • The judgment ordered Amihan Bus Lines to pay:
      • ₱800,000.00 as actual damages.
      • ₱25,000.00 as exemplary damages.
      • ₱20,000.00 as attorney’s fees and litigation expenses.
      • The costs of the suit.
    • A writ of execution was issued upon Romars’ motion, and the defendant’s subsequent motion for reconsideration was denied.
  • Appellate Proceedings and Grounds for Petition
    • Amihan Bus Lines (now petitioner) elevated the case to the Court of Appeals seeking annulment of:
      • The RTC decision dated April 17, 2007, which found it liable for damages.
      • The RTC Order dated January 18, 2007, which denied the defendant’s motion to present evidence.
      • The RTC Order dated June 26, 2007, granting Romars’ motion for execution.
    • Grounds raised by the petitioner included:
      • Allegations of extrinsic fraud due to the gross negligence and incompetence of its former counsel.
      • Claim of grave abuse of discretion (or lack/excess of jurisdiction) in not reconsidering minor procedural orders.
      • Assertion that the execution proceedings were null and void because of non-compliance with procedural rules regarding service of the decision.
    • The CA dismissed the petition outright, finding the allegations meritless.

Issues:

  • Whether the petitioner’s claim that extrinsic fraud, hinging on the gross negligence of its former counsel, justifies the annulment of the RTC decision.
    • Examining if the absence of the petitioner’s counsel during certain proceedings constitutes extrinsic fraud.
    • Considering if the alleged negligence can be attributed to a fraudulent act by the opposing party.
  • Whether the RTC’s and CA’s proceedings conformed with due process, particularly in light of the petitioner’s failure to timely act on notifications and court orders.
    • Assessing if the petitioner was deprived of an opportunity to fully exhibit its case due to any fraudulent concealment or deception by the respondent.
    • Evaluating the legitimacy of the execution proceedings in the absence of proper service of the RTC decision.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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