G.R. No. L-35697-99 - De Lima vs. Laguna Tayabas Co.

A collision occurred on June 3, 1958, involving a passenger bus operated by Laguna Tayabas Bus Co. (LTB) and a delivery truck of Seven-Up Bottling Co. of the Philippines.
As a result of the collision, Petra de la Cruz was killed, while Eladia de Lima and Nemesio Flores suffered serious physical injuries.
Three separate civil actions were filed against the respondents, which were subsequently consolidated for trial before the Court of First Instance of Laguna in San Pablo City.

On December 27, 1963, the trial court rendered judgment awarding damages against the defendants.
In Civil Case No. SP-239 (plaintiff Eladia de Lima), the award included:

Compensation for the death of Petra de la Cruz including funeral expenses amounting to P3,883.82.
Money lost during the trip amounting to P800.00.
Moral damages for mental anguish of P3,000.00.
Loss of earning capacity for 5 years valued at P8,000.00.
Expenses of litigation and attorney’s fees amounting to P2,500.00.
A total award of P18,183.82.

Loss of earning capacity for 5 years from June 3, 1958 at a rate of P228.00 per month, totaling P13,680.00.
Expenses of litigation and attorney’s fees amounting to P1,000.00.
A total award of P14,680.00.

Plaintiffs in Cases Nos. SP-239 and SP-240 filed a motion for reconsideration seeking an award of legal interest from the date of the trial court’s decision; however, the court a quo did not act on this motion.
The plaintiffs voluntarily desisted from appealing the trial court’s decision due to financial necessity and in the hope that the transportation company (LTB Co.) would promptly pay the awarded amounts.
The defendants, dissatisfied with the trial court’s decision, opted to appeal to the Court of Appeals.
On December 29, 1971, petitioners submitted a motion to the Court of Appeals requesting:

Immediate adjudication of the case.
An order for legal interest on the awarded amounts to run from the trial court’s decision date (December 27, 1963) instead of the appellate decision date (January 31, 1972).
An increase in the civil indemnity for the death of Petra de la Cruz from P3,000.00 to P12,000.00.

The Court of Appeals promulgated its decision on January 31, 1972.
Petitioners then moved for a reconsideration of the appellate decision, seeking a modification regarding the start date of legal interest and an increased indemnity for the death of Petra de la Cruz.

Whether legal interest should run from the date of the trial court’s decision or from the date of the Court of Appeals’ decision.
Whether the civil indemnity for the death of Petra de la Cruz should be increased beyond the P3,000.00 awarded by the trial court.

The petitioners argued for the application of a liberal and equitable approach, noting that:

Plaintiffs had sought interest in their earlier motions, and only one plaintiff (Nemesio Flores) had expressly reiterated the claim in his brief.
The delay in final adjudication and the appellants’ indigence warranted a reconsideration on substantive grounds rather than purely technical ones.

The plaintiffs’ failure to timely appeal certain aspects of the trial court’s decision should preclude any modification or additional relief on technical grounds.
The awarding of legal interest from the Court of Appeals’ decision was within the discretion of that court.

Should the legal interest on the damages awarded commence from the date of the trial court’s decision (December 27, 1963) or from the date of the Court of Appeals’ decision (January 31, 1972)?

Should the civil indemnity for the death of Petra de la Cruz be increased from the trial court’s awarded amount of P3,000.00 to a higher sum, as prayed for by the petitioners?