Title
Estate of Hassan vs. Canla
Case
G.R. No. L-2478
Decision Date
Jul 27, 1950
Primitivo Cania claimed unpaid wages from Abaul Hassan’s estate for coal prospecting. Trial court awarded P994.01; Court of Appeals increased it to P3,819.01. Supreme Court reversed, reinstating P994.01, ruling appellee cannot seek higher award without appeal.
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Case Digest (G.R. No. L-2478)

Facts:

  1. Employment Agreement:

    • The respondent, Primitivo Cania, filed a claim for P2,667 against the estate of the deceased Abaul Hassan.
    • The claim was based on two documents, Exhibits A and B.
    • Exhibit A was a certification dated July 31, 1939, signed by Abaul Hassan, stating that Cania was employed as a coal prospector with a remuneration of P0.50 per ton of coal extracted.
  2. Claim Details:

    • Exhibit B was a detailed statement of account showing the tons of coal extracted monthly from January 1941 to March 1942, the corresponding share of Cania at P0.50 per ton, the amounts paid, and the balance payable.
    • The total balance claimed was P2,667.
  3. Trial Court Decision:

    • The trial court approved the claim but reduced the amount to P994.01, ordering the administrator of the estate to pay this amount to Cania.
  4. Court of Appeals Decision:

    • The Court of Appeals modified the trial court's decision, increasing the amount awarded to Cania from P994.01 to P3,819.01.
  5. Appeal to the Supreme Court:

    • The administrator of the estate appealed the Court of Appeals' decision to the Supreme Court, arguing that the Court of Appeals erred in increasing the award.

Issue:

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Ruling:

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Ratio:

  1. Finality of Findings of Fact:

    • The findings of fact by the Court of Appeals, based on the evidence presented, are conclusive and binding on the Supreme Court.
  2. Limitations on Appellee's Role:

    • An appellee who does not appeal from a trial court's judgment cannot seek a modification or increase in the award. Such relief can only be granted if the appellee files an appeal.
  3. Clerical vs. Judicial Errors:

    • The Court of Appeals incorrectly characterized the trial court's alleged error as clerical. The error, if any, was judicial and could only be corrected through an appeal by the adversely affected party.
  4. Harmless Error Rule:

    • The harmless error rule (Rule 53, Section 3) does not authorize an appellate court to modify a judgment in favor of a party who has not appealed.


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