Case Digest (G.R. No. 221439)
Facts:
This case arose from the demolition of a commercial fish center situated on a 284-square-meter property in Poblacion, Dagupan City, which was under a miscellaneous lease contract with the Department of Environment and Natural Resources (DENR) held by respondent Ester F. Maramba. Maramba constructed the commercial fish center on the property in 1974. On December 20, 2003, petitioner, the City of Dagupan, represented by then Mayor Benjamin S. Lim, caused the demolition of the fish center allegedly without giving direct notice to Maramba and under threat of property takeover. Maramba, through her attorney-in-fact Johnny Ferrer, filed a complaint for injunction and damages, praying for both actual and moral damages, plus attorney’s fees. Although Maramba’s complaint initially inconsistently stated damages of P10,000 and P10,000,000.00 with handwritten corrections, the trial court eventually awarded a total of P11 million in damages: P10 million as actual damages, P500,000 as moral
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Case Digest (G.R. No. 221439)
Facts:
- Parties and Nature of Case
- The petitioner is the City of Dagupan, represented by then-Mayor Benjamin S. Lim.
- The respondent is Ester F. Maramba, represented by her attorney-in-fact Johnny Ferrer.
- The case involves a property dispute and damages stemming from demolition of a commercial fish center.
- Background
- Maramba was a lessee of a 284-square-meter property in Poblacion, Dagupan City, under a Department of Environment and Natural Resources (DENR) miscellaneous lease contract for 25 years.
- In 1974, Maramba constructed a commercial fish center on the leased property.
- Incident
- On December 20, 2003, the City of Dagupan demolished the commercial fish center allegedly without directly notifying Maramba and with a threat of taking over the property.
- Maramba, through her attorney-in-fact, filed a complaint for injunction and damages seeking a writ of preliminary injunction or temporary restraining order, claiming unlawful demolition and damages allegedly valued at Ten Million Pesos (handwritten intercalations suggested more than the printed amount).
- Trial Court Proceedings and Rulings
- On July 30, 2004, the Regional Trial Court (RTC), Branch 44, Dagupan City, ruled in favor of Maramba, awarding:
- Ten Million Pesos (₱10,000,000.00) actual damages for the demolition.
- Five Hundred Thousand Pesos (₱500,000.00) as moral damages.
- Five Hundred Thousand Pesos (₱500,000.00) for attorney’s fees.
- Permanent writ of preliminary injunction against the City of Dagupan.
- The City's motion for reconsideration, filed on August 26, 2004, was opposed by Maramba on the ground that it lacked a notice of hearing.
- On October 21, 2004, the trial court denied the motion for reconsideration for lack of notice and considered the motion not entitled to judicial cognizance.
- Petition for Relief from Judgment
- The City of Dagupan filed a petition for relief from judgment (Rule 38) on October 29, 2004, alleging counsel’s mistake and negligence had led to an unconscionable award.
- The trial court initially denied this petition on November 18, 2004, stating counsel’s negligence binds the client.
- On reconsideration, on August 25, 2005, the trial court granted the petition for relief, modifying the damage award:
- Actual damages reduced from ₱10 million to ₱75,000.00 (based on appraised value proven by Maramba).
- Moral damages reduced from ₱500,000.00 to ₱20,000.00.
- Attorney’s fees reduced from ₱500,000.00 to ₱20,000.00.
- The writ of execution was recalled.
- Appeal and Court of Appeals Decision
- Maramba filed a petition for certiorari before the Court of Appeals (CA), arguing the trial court judge that granted the petition for relief acted without jurisdiction and gravely abused discretion.
- On June 15, 2006, the CA granted Maramba’s petition, holding:
- The City’s motion for reconsideration lacked notice of hearing and was a mere scrap of paper not tolling the period to appeal.
- Consequently, the original July 30, 2004 RTC decision became final and executory.
- CA denied reconsideration, prompting the City to elevate the case to the Supreme Court.
- Supreme Court Discussion and Procedural Facts
- The City admitted lack of notice of hearing due to counsel’s oversight but invoked excusable negligence.
- Both parties presented various jurisprudence regarding:
- The finality of judgments.
- Effects of lack of notice in motions for reconsideration.
- Grounds and procedures for relief under Rule 38.
- Necessity of proving actual damages.
- The City asserted the damages awarded were excessive and unproven.
- Maramba maintained the award was proper and supported by testimony, and that lack of notice cannot be excused.
Issues:
- Whether the lack of notice of hearing in a motion for reconsideration constitutes excusable negligence that allows the filing of a petition for relief from judgment under Rule 38.
- Whether the petition for relief from judgment filed within 60 days from receipt of denial of the motion for reconsideration was timely.
- Whether courts have legal power to amend or correct a final and executory judgment even if erroneous.
- Whether an award of actual damages must be substantiated with competent evidence to be valid.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)