Case Digest (G.R. No. 122947)
Facts:
Rafael S. Dizon, in his capacity as Administrator of the Estate of the Deceased Jose P. Fernandez, Redentor Melo, Eliodoro C. Cruz, Pier 8 Arrastre & Stevedoring Services, Inc., Compania Maritima, Pasig Stevedoring Company, Inc., and Western Pacific Corporation v. Hon. Court of Appeals, Hon. Protacio C. Sto. Tomas, Judge, RTC, Branch 14, Ligao, Albay, and Jose Balde, G.R. No. 96296. June 18, 1992, Supreme Court Second Division, Narvasa, C.J., writing for the Court.In 1975 Jose Balde (private respondent) filed Civil Case No. 528-LV in the Court of First Instance (now the Regional Trial Court) at Ligao, Albay, seeking money damages for alleged summary dismissal from employment by the so-called “Fernandez Companies.” The complaint named several corporate petitioners and individuals, including Jose P. Fernandez (the principal), and alleged acts by corporate officials that led to Balde’s ouster and a prayer for actual, moral and exemplary damages (no prayer for reinstatement).
The defendants repeatedly moved to dismiss for lack of jurisdiction (asserting the dispute was a labor/money claim exclusively cognizable by the National Labor Relations Commission/Labor Arbiters) and for improper venue; the trial court initially held such motions in abeyance and the case proceeded to pre-trial and trial. The defendants filed an Answer with Compulsory Counterclaim; Balde completed his evidence-in-chief and his exhibits were admitted on October 21, 1987.
On November 7, 1987 Jose P. Fernandez died; notice of his death was filed November 16, 1987. Rather than dismiss the action as to the deceased under the Rules of Court applicable to money claims, the trial court repeatedly required substitution of the deceased's legal representative/administrator — initially directing counsel (former Justice Arsenio P. Dizon) to effect substitution (Order, Nov. 21, 1987), later directing the administrator himself to appear for substitution (Order, Jan. 2, 1989); the judge treated Section 17, Rule 3 substitution procedure as appropriate despite the character of the claim.
A sequence of calendar and service problems followed. The trial court set, reset and, on April 24, 1989, declared the case submitted for decision because defendants/counsel failed to appear. Subsequent motions to reconsider and procedural skirmishing continued (Orders of March 31, April 24, May 9, Oct. 17 and Oct. 25, 1989, and a December 6, 1989 Order denying a motion for reconsideration). Petitioners explained nonappearance at the December hearing by citing the December 1989 aborted coup d’état and resultant suspension of domestic flights; they also urged dismissal as to the deceased under the Rules.
The petitioners filed a special civil action for certiorari in the Court of Appeals (docketed CA-G.R. SP No. 19602) to annul the trial court’s ...(Pro-only)
Issues:
- Did the trial court err in refusing to dismiss the action as to the deceased Jose P. Fernandez and instead ordering substitution, in violation of the Rules of Court?
- Was the trial court justified in denying the petitioners’ repeated motions for reconsideration of interlocutory orders on the ground that a “second motion for reconsideration” is categorically impermissible?
- Did the petitioners have justifiable cause for failing to appear at scheduled hearings (notably December 6, 1989)?
- Did the Regional Trial Court have subject-matter jurisdiction over Balde’s complaint, or did...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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