Title
Autographics, Inc. vs. Court of Appeals
Case
G.R. No. 95863
Decision Date
Jul 1, 1993
AGI sued PAL for damages after contract termination; trial court denied PAL's evidence presentation, deemed abuse of discretion. SC affirmed CA, remanded for proper evidence reception.
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Case Digest (G.R. No. 95863)

Facts:

Contractual Relationship

  • Petitioner Autographics, Inc. (AGI) and private respondent Philippine Airlines, Inc. (PAL) entered into several contracts where AGI provided support services to PAL, including vehicles, maintenance, and insurance coverage. PAL agreed to pay AGI a semi-monthly contract price.

Termination of Contracts

  • While the contracts were still in force, PAL notified AGI of their termination, claiming the contracts were prejudicial to PAL's interests and violated its franchise.

Filing of Complaint

  • On 25 January 1989, AGI filed a complaint against PAL before the Regional Trial Court (RTC) of Cebu to recover ₱30,000,000.00 in damages, with a request for preliminary attachment and injunction.

Preliminary Attachment and PAL's Response

  • The RTC issued a writ of preliminary attachment over PAL's properties. PAL filed a petition for certiorari and prohibition with the Court of Appeals (CA) to challenge the writ, and the CA issued a temporary restraining order (TRO) to halt the attachment.

Amended Complaints and Trial Proceedings

  • AGI filed amended complaints, and the trial court admitted them. PAL filed its answer and counterclaim. The trial court issued an alias writ of preliminary attachment, and PAL posted a counterbond.

Trial and Evidence Presentation

  • AGI presented its evidence from 16 August 1989 to 8 November 1989, offering 382 exhibits. PAL's scheduled hearing dates were postponed due to a typhoon and the unavailability of witnesses.

Deposition Request

  • PAL filed a Manifestation/Motion on 14 December 1989, requesting to take depositions of its witnesses due to their unavailability for in-person testimony. The trial court did not act on this request.

Waiver of PAL's Right to Present Evidence

  • On 20 December 1989, PAL's counsel sought a resetting of the hearing due to the unavailability of its principal counsel and witnesses. The trial court granted AGI's motion to consider PAL's right to present evidence waived and declared the case submitted for decision.

Trial Court's Decision

  • On 28 December 1989, the trial court rendered a decision adverse to PAL. PAL filed a motion for reconsideration, which was denied on 12 January 1990.

Appeal to the Court of Appeals

  • PAL filed a petition for certiorari with the CA, which granted the petition, nullified the trial court's orders and decision, and remanded the case for further reception of evidence.

Supreme Court Petition

  • AGI filed a petition for review with the Supreme Court, challenging the CA's decision. The Supreme Court denied AGI's petition, affirming the CA's ruling.

Issue:

  1. Whether the trial court committed grave abuse of discretion in issuing the oral Order of 20 December 1989 and rendering the decision of 28 December 1989 without allowing PAL to present evidence.
  2. Whether the trial court's decision had become final and executory due to PAL's abandonment of its right to appeal by filing a special civil action for certiorari.
  3. Whether res judicata applies in view of a prior Supreme Court ruling (G.R. No. 93211).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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