Case Digest (G.R. No. 225151) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1952, during the hearing of Civil Case No. 2293 in the Court of First Instance of Manila (Francisco Sycip vs. National Coconut Corporation), Assistant Corporate Counsel Federico Alikpala requested stenographic transcripts from court stenographers Leopoldo T. Bacani and Mateo A. Matoto. The plaintiffs delivered 714 pages of transcript at ₱1 per page and billed ₱564 to Bacani and ₱150 to Matoto. The National Coconut Corporation (NCC) paid these amounts, but upon audit the Auditor General disallowed the fees and, citing a Department of Justice circular, demanded reimbursement on January 19, 1953. When no refund was made, the Auditor General ordered on February 6, 1954 salary deductions of ₱25 per payday from Bacani and ₱10 per payday from Matoto. To halt these deductions and secure a declaration that the NCC was not a “government entity” exempt under Rule 130, Section 16 of the Rules of Court, the stenographers filed an action in the CFI of Manila. The trial court ruled in their Case Digest (G.R. No. 225151) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Plaintiffs-Appellees
- Leopoldo T. Bacani and Mateo A. Matoto, court stenographers, Branch VI, Court of First Instance, Manila.
- Defendants-Appellants
- National Coconut Corporation (NCC) and Board of Liquidators; Auditor General’s office enforcing refund.
- Transcript Request and Payment
- During Civil Case No. 2293 (Francisco Sycip vs. NCC), Assistant Corporate Counsel requested transcript of stenographic notes (714 pages).
- Plaintiffs delivered transcript and billed P1.00 per page; NCC paid P564 to Bacani and P150 to Matoto (total P714).
- Auditor General’s Disallowance and Salary Deduction
- Auditor General, citing DOJ circular, held NCC exempt from fee liability under section 16, Rule 130, Rules of Court.
- On January 19, 1953, plaintiffs were required to reimburse; on February 6, 1954, orders issued to deduct P25/payday from Bacani and P10/payday from Matoto.
- Trial Court Proceedings
- Plaintiffs filed a petition for prohibition to enjoin salary deduction and declare NCC not a government entity under Rule 130.
- The Court of First Instance of Manila ruled:
- NCC is not a government entity within section 16, Rule 130.
- Payments made were valid and legal.
- Plaintiffs have no obligation to refund.
- Defendants appealed to the Supreme Court.
Issues:
- Whether the National Coconut Corporation is a “Government of the Philippines” entity exempt from stenographers’ fees under section 16, Rule 130 of the Rules of Court.
- Whether the negotiated payment of P1.00 per page, in excess of statutory rates, is valid and enforceable.
- Whether the petition for prohibition was the proper remedy to prevent salary deductions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)