Case Digest (G.R. No. 64591)
Facts:
- Rufino Co is the petitioner, while Hon. Eficio B. Acosta (Presiding Judge, RTC Branch CLV, Pasig), Refrigeration Industries, Inc. (RII), and Delta Motors Corporation are the respondents.
- On November 20, 1979, PEPSI issued three purchase orders to CTC Appliance Center, owned by Rufino Co, for 12,000 refrigerators valued at P35,322,900.00.
- Rufino Co assigned his rights in these orders to RII on November 21, 1979, through a formal deed of assignment.
- On March 9, 1981, PEPSI informed RII that it did not recognize the assignment.
- Despite this, RII delivered and was paid for 10,000 units.
- PEPSI requested an additional 1,000 units on March 18, 1981, which RII delivered from March 23 to May 21, 1981, totaling P2,907,535.00.
- RII sent demand letters to PEPSI, which were refused, leading RII to demand payment from Rufino Co on July 8, 1981, but he also refused.
- RII and Delta Motors filed Civil Case No. 42815 against PEPSI and Rufino Co on September 10, 1981.
- The court dismissed the case against PEPSI on November 26, 1981, upon RII's ex-parte motion.
- RII filed a motion to declare Rufino Co in default on November 19, 1982, which the court granted, allowing RII to present evidence ex-parte.
- On March 9, 1983, the court ruled in favor of RII and Delta Motors, ordering Rufino Co to pay P2,907,535.00 plus interest and fees.
- Rufino Co's "Petition for Relief from Judgment" filed on April 12, 1983, was denied, leading to a writ of execution against his properties.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Rufino Co, granting the petition and annulling the RTC proceedings following the dismissal of the complaint against PEPSI.
- The Court ordered that the effects of the dismissal be extended...(Unlock)
Ratio:
- The Court determined that both Rufino Co and PEPSI were indispensable parties in the case, as they were involved in a common cause of action.
- The dismissal of the case against PEPSI without notifying Rufino Co was improper, denying him the chance to defend himself.
- Citing Lim Tanhu v. Hon. Ramolete, the Court emphasized that the dismissal...continue reading
Case Digest (G.R. No. 64591)
Facts:
The case involves Rufino Co as the petitioner and Hon. Eficio B. Acosta, in his official capacity as Presiding Judge of the Regional Trial Court (RTC), Branch CLV, Pasig, Metro Manila, along with Refrigeration Industries, Inc. (RII) and Delta Motors Corporation as respondents. The events leading to this case began on November 20, 1979, when Pepsi Cola Bottling Company of the Philippines, Inc. (PEPSI) issued three purchase orders to CTC Appliance Center, owned by Rufino Co, for 12,000 units of refrigerators valued at P35,322,900.00. On November 21, 1979, Rufino Co assigned his rights and interests in these purchase orders to RII through a formal deed of assignment. However, on March 9, 1981, PEPSI informed RII that it did not recognize the assignment.
Despite this, 10,000 units were delivered and paid for without issue. On March 18, 1981, PEPSI requested an additional 1,000 units, which were delivered directly by RII from March 23 to May 21, 1981, amounting to P2,907,535.00. Following a series of demand letters from RII to PEPSI, which were met with refusals to pay, RII demanded payment from Rufino Co on July 8, 1981, but he also refused. Consequently, RII and Delta Motors filed Civil Case No. 42815 against PEPSI and Rufino Co on September 10, 1981.
On November 26, 1981, the court dismissed the case against PEPSI upon RII's ex-parte motion, which included a joint release and waiver of liabilities among the parties. Subsequently, on November 19, 1982, RII filed a motion to declare Rufino Co in default for not answering the complaint. The court granted this motion on November 22, 1982, allowing RII to present evidence ...