Case Digest (G.R. No. 213286) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case titled E. RAZON, INC. vs. THE HONORABLE JOSE L. MOYA, JUDGE OF THE COURT OF FIRST INSTANCE OF MANILA (BRANCH X) AND HARTFORD FIRE INSURANCE COMPANY involves an appeal by Certiorari concerning the decision rendered by the Court of Appeals on November 24, 1969. The case stems from an earlier matter where Hartford Fire Insurance Co. (the petitioner) filed Civil Case No. 75781 against E. Razon, Inc. among others on February 20, 1969, before the Court of First Instance of Manila. The case was assigned to Judge Jose L. Moya. On May 19, 1969, during a pre-trial conference, the parties reached several stipulations regarding the incident involving a shipment. It was agreed that the cargo was discharged into the custody of E. Razon, Inc., but was never delivered to the consignee, International Textile Mills, Inc. The plaintiff consequently withdrew the complaint against two other defendants.
The remaining issue was whether a Revised Management Contract applied in this case, due
Case Digest (G.R. No. 213286) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On February 20, 1969, Hartford Fire Insurance Co. initiated Civil Case No. 75781 before the Court of First Instance of Manila against petitioner E. Razon, Inc. for a monetary claim.
- The case involved a shipment discharged by the SS’ Yamanashi Maru into the custody of E. Razon, Inc., which, however, failed to be delivered to the intended consignee, International Textile Mills, Inc.
- During a pre-trial conference held on May 19, 1969, the parties agreed to a number of stipulations including:
- The acknowledgment that despite the cargo being received, it was not delivered by E. Razon, Inc. to the consignee.
- The plaintiff’s withdrawal of its complaint as against other defendants, narrowing the dispute exclusively to the matter between Hartford Fire Insurance Co. and E. Razon, Inc.
- That the sole issue was whether the Revised Management Contract was applicable, noting that the consignee’s formal claim was filed after the contractual deadline.
- E. Razon, Inc.’s admission under the First Cause of Action for specific allegations as set out in the stipulations.
- The submission of the case for decision upon the filing of memoranda by both parties within a twenty-day period.
- Decision at the Trial Court
- After the submission of memoranda, respondent Judge rendered a Decision on July 11, 1969.
- The Decision held that the Revised Management Contract did not apply due to the total non-delivery of the shipment, resulting in the condemnation of petitioner E. Razon, Inc. to pay Hartford Fire Insurance a sum slightly exceeding P8,000.00.
- Although a copy of the Decision was received on July 18, 1969, no document of the Decision was later produced in the record.
- Appeal and Subsequent Proceedings
- E. Razon, Inc. filed its Notice of Appeal on August 7, 1969 and duly submitted its Record on Appeal on August 15, 1969.
- Hartford’s counsel moved to dismiss the appeal on August 27, 1969, arguing that because only a question of law was involved, the appeal should have been filed by Certiorari to the Supreme Court.
- On August 30, 1969, respondent Judge dismissed the appeal on the ground that the appellate court was limited to resolving questions of law and that the required petition for Certiorari had not been filed.
- Recognizing that the dismissal order was issued prematurely, respondent Judge set aside the August 30 Order on September 8, 1969, yet maintained the dismissal stance.
- At the hearing on September 6, 1969, defendant’s counsel contended that issues of fact were intended to be revived on appeal; however, the Judge reiterated that the case was decided solely on the stipulations of facts agreed upon by the parties.
- Consequently, the appeal was definitively dismissed, and on September 13, 1969, respondent Judge ordered the execution of the Decision, deeming it "final and executory."
- Petitioner's subsequent plea for reconsideration was denied, prompting E. Razon, Inc. to file an original action for Mandamus on September 20, 1969, before the Court of Appeals to compel approval of its appeal.
- On November 24, 1969, the Court of Appeals denied the Petition for Mandamus, holding that in cases involving only questions of law, the appeal should have been by review on Certiorari to the Supreme Court.
- Concurrence and Additional Observations
- Justice Teehankee, in a concurring opinion, noted that since the approval of Republic Act No. 5440 on September 9, 1968, appeals on questions of law should be brought by petition for review on Certiorari rather than as a right by record on appeal.
- He characterized petitioner’s insistence on a record appeal as frivolous and dilatory, reinforcing the Court’s decision denying mandamus.
Issues:
- Proper Mode of Appellate Review
- Whether an appeal on matters involving only questions of law should have been filed by Certiorari to the Supreme Court rather than by record on appeal to the Court of Appeals.
- The adequacy of the trial court’s dismissal of the appeal based solely on the nature of the issues (purely questions of law).
- Mandamus as a Remedy
- Whether the petition for Mandamus, seeking to compel the trial court to approve the appeal, was a proper and effective remedy under the circumstances.
- Whether dismissing the appeal, despite a procedural lapse, resulted in any substantial injustice to the petitioner.
- Applicability of the Revised Management Contract
- Whether the contractual stipulation regarding timely filing (30-day period) precluded the application of the Revised Management Contract given the fact of total non-delivery of the shipment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)