Facts:

The case involves a petition by Serena T. Bacelonia, Graciano Bacelonia, Sr., and Graciano T. Bacelonia, Jr. (hereinafter referred to as the petitioners) against the Court of Appeals and spouses Victorino S. Bolos, Jr. and Olivia P. Bolos (the respondents). The incident that gives rise to this case is a vehicular accident that occurred on February 3, 1993, along Aurora Boulevard in Quezon City, which caused the death of the private respondents' daughter, Jemelee Bolos. This vehicle collision involved a tamaraw-type school shuttle service vehicle owned by the petitioners and a 6 x 6 Isuzu cargo truck operated by their co-defendants, Simeon Roxas-Cu and Daniel CariAo. On January 12, 1998, the private respondents filed a complaint for damages against the petitioners and their co-defendants in the Regional Trial Court of Quezon City, registered as Civil Case No. Q-98-33149.

Prior to this, on March 1, 1995, the petitioners had filed a separate complaint against their co-defendant

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Facts:

Background of the Case

• On February 3, 1993, a vehicular accident occurred along Aurora Blvd. in Quezon City involving a tamaraw-type school shuttle service vehicle and a 6x6 Isuzu cargo truck. The accident resulted in the death of Jemelee Bolos, who was a passenger in the school shuttle service vehicle.

Parties Involved

• Petitioners: Serena T. Bacelonia, Graciano Bacelonia, Sr., and Graciano Bacelonia, Jr. (owners/operators of the school shuttle service and its driver, respectively).
• Respondents: Spouses Victorino S. Bolos, Jr. and Olivia P. Bolos (parents of Jemelee Bolos).
• Co-Defendants: Simeon Roxas-Cu (owner of the cargo truck) and Daniel CariAo (driver of the cargo truck).

Legal Proceedings

1. First Case (Civil Case No. Q-95-23169):

   • On March 1, 1995, the Bacelonias filed a complaint for damages against Simeon Roxas-Cu and Daniel CariAo arising from the same accident.
   • On April 27, 1995, the parties entered into a compromise agreement, leading to the dismissal of the case on April 28, 1995.

2. Second Case (Civil Case No. Q-98-33149):

   • On January 12, 1998, the Bolos spouses filed a complaint for damages against the Bacelonias, Simeon Roxas-Cu, and Daniel CariAo.
   • The Bacelonias filed their answer on February 9, 1998, raising the compromise agreement as a defense.
   • On September 24, 1999, the Bacelonias filed a motion to be dropped as defendants, arguing that the compromise agreement in the first case absolved them of liability.
   • The trial court denied the motion on January 10, 2000, and scheduled the defense's evidence presentation for February 3, 2000.
   • On January 31, 2000, the Bacelonias filed a motion for reconsideration and a motion to cancel the February 3, 2000 hearing.
   • On February 3, 2000, the trial court denied the motion for reconsideration and proceeded with the hearing.

3. Appeal to the Court of Appeals:

   • The Bacelonias filed a petition for certiorari with the Court of Appeals, which dismissed it on March 6, 2000, for being premature and lacking merit.
   • The motion for reconsideration was also denied on May 19, 2000.

4. Supreme Court Petition:

   • The Bacelonias filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals exceeded its jurisdiction and violated their right to due process.

Issue:

1. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for certiorari.
2. Whether the trial court violated the Bacelonias' right to due process by denying their motion for reconsideration without a hearing.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court upheld the decisions of the lower courts, ruling that the Bacelonias were not denied due process and that their motions were properly denied for being dilatory and non-compliant with procedural rules.