G.R. No. 179232 - Del Monte Fresh Produce N.A vs. Dow Chemical Co.

On August 11, 1995, a Joint Complaint for damages based on quasi-delict was filed before the RTC of Panabo City, Davao del Norte, by 1,185 individuals (later amended to 1,843 plaintiffs).
The complaint alleged that various corporations—including Del Monte Fresh Produce, N.A.; Del Monte Tropical Fruit Company; Dow Chemical Company; Occidental Chemical Corporation; Shell Oil Company; Standard Fruit and Steamship Company; Standard Fruit Company; Dole Food Company, Inc.; Dole Fresh Fruit Company; Chiquita Brands, Inc.; Chiquita Brands International; among others—were negligent in manufacturing, distributing, and/or selling the chemical dibromochloropropane (DBCP), or in failing to warn about its hazardous effects.
The plaintiffs, primarily banana plantation workers and residents of Davao del Norte, claimed exposure to DBCP in the early 1970s and 1980s, which allegedly caused them serious and permanent health injuries.

Prior to the defendants’ submission of their Answers, the Joint Complaint was amended to include additional plaintiffs and to remove certain parties, thereby changing the composition of the case.
Multiple defendants filed separate Answers with their respective counterclaims:

Dow Chemical Company and Occidental Chemical Corporation (the Dow/Occidental defendants) filed an Answer that included a counterclaim and moved for dismissal based on a compromise agreement with the plaintiffs.
Chiquita defendants filed a Motion for Leave to Admit an Amended Answer with Counterclaims and Cross-claims invoking inadvertence and excusable neglect.
Del Monte defendants submitted motions to amend their Answer to include cross-claims against their co-defendants, claiming inadvertence in omission.
Dole defendants later filed a Motion to Admit an Amended Answer with an accompanying Cross-claim, arguing they needed to secure their right to contribution as potential solidary debtors.

On September 2, 1997, the Dow/Occidental defendants jointly moved to dismiss the complaint against them, asserting that they had entered into a compromise agreement with the plaintiffs and simultaneously filed a Motion for Partial Judgment Based on Compromise.
The Chiquita and Del Monte defendants, among others, undertook motions to amend their pleadings to include or correct cross-claims, thereby engaging in a series of oppositions and replies regarding the admissibility and timing of these amendments.
On June 4, 2001, the Del Monte defendants filed a Motion to Dismiss portions of the Amended Joint Complaint, arguing that many of the plaintiffs’ claims had already been paid, waived, or settled, and attaching a “Release in Full” settlement agreement.
The Dow/Occidental defendants later issued a Request for Admissions on June 4, 2002, seeking confirmation from the plaintiffs regarding previous payments under the compromise agreements.

Approved various amended answers and motions, including those of the Chiquita, Del Monte, and Dole defendants.
Incorporated and approved, by way of judgment on compromise, the settlement or compromise agreements between the plaintiffs and the Dow/Occidental defendants.
Recognized and preserved the continuity of the cross-claims among the co-defendants.

A subsequent Motion for Partial Reconsideration by the Dow/Occidental defendants was filed and denied.
On December 26, 2002, plaintiffs filed a Motion for Execution based on alleged noncompliance with the compromise agreements, leading to the issuance of a Writ of Execution on April 23, 2003 that mandated the execution of the judgment based on these agreements.

The case was consolidated into petitions for review on certiorari before the Supreme Court, with the petitions challenging both the May 23, 2006 Decision and the August 8, 2007 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 77287.
The CA ruled on several motions:

It partially granted the petition by modifying the Omnibus Order regarding the admission and dismissal of cross-claims.
It upheld the validity of the cross-claims filed by the Dole, Del Monte, and Chiquita defendants as duly filed with the leave of court before judgment.
It determined that the dismissal of the civil case against the Dow/Occidental defendants based on compromise agreements did not automatically result in the dismissal of cross-claims against them.
It found that the RTC abused its discretion by admitting the cross-claims against the Dow/Occidental defendants without proper qualification.

The Dow/Occidental defendants, unsatisfied with the CA’s findings—including the propriety of their Request for Admission—filed petitions for review with the Supreme Court, which ultimately denied the petition for lack of merit.

Whether the dismissal of the civil complaint against the Dow/Occidental defendants due to compromise agreements automatically resulted in the dismissal of the cross-claims filed against them.
Whether the cross-claims of the Dole, Del Monte, and Chiquita defendants, filed with leave and before judgment as provided under Section 10, Rule 11 of the 1997 Rules of Civil Procedure, were properly admitted.
Whether the RTC committed reversible error or grave abuse of discretion by admitting the cross-claims against the Dow/Occidental defendants without qualifications, particularly when some defendants had settled with certain plaintiffs.
Whether the Request for Admission issued by the Dow/Occidental defendants, which sought to obtain the plaintiffs’ acknowledgment of payments under the compromise agreements, was proper and timely.
Whether the distinction between the settled (compromised) and non-settled plaintiffs affects the viability and scope of the cross-claims against the respective defendants.