Case Digest (G.R. No. 219408) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 21, 2011, Donald Francis Gaffney filed a Complaint for sum of money against Gina V. Butler in the Regional Trial Court (RTC) of Pasig City, Branch 70, Civil Case No. 73187. Gaffney alleged that between 2006 and 2007 he invested approximately ₱12,500,000.00 in ActiveFun Corporation, where Butler was President and her late husband, Anthony Richard Butler, was CEO. After Anthony’s death in December 2009, the investment agreement failed to materialize. Butler personally undertook to repay the investment plus interest but paid only ₱1,000,000.00 on October 15, 2010, which Gaffney claimed was acknowledged by a receipt he later disputed as a forgery. Numerous demands went unheeded and, on October 1, 2012, Gaffney secured leave to file an Amended Complaint to implead Anthony’s estate as an additional defendant, allegedly represented by Gina as surviving spouse. Gina filed a Motion to Dismiss ad cautelam and Gaffney moved to declare her in default. On August 15, 2013, and No Case Digest (G.R. No. 219408) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- On September 21, 2011, Donald Francis Gaffney (“private respondent”) filed a complaint for sum of money against Gina V. Butler (“petitioner”), alleging an approximate PhP 12,500,000.00 investment in ActiveFun Corporation (Gina as President; her husband Anthony Richard Butler as Treasurer/CEO) during 2006–2007.
- Anthony died in December 2009; the proposed investment agreement did not materialize, and Gina personally undertook to repay the investment with interest.
- Payments and pre-litigation demands
- On October 15, 2010, Gina paid PhP 1,000,000.00, acknowledged by a receipt disputed by Gina as forgery; further demands by phone, e-mail, and a registered-mail letter (July 13, 2011) for PhP 25,000,000.00 plus interest went unheeded.
- In her August 2, 2011 letter, Gina denied knowledge of any investment obligation and averred the PhP 1,000,000.00 was an “undue payment” made under intimidation.
- Documentary dispute and amendment of complaint
- During pre-trial, Gina pre-marked two receipts: one formal acknowledgment and one handwritten note stating the PhP 1,000,000.00 was owed by Anthony, not Gina. Gina denied signing the formal receipt.
- Donald moved to file an amended complaint to implead Anthony’s estate (represented by Gina as surviving spouse) to secure “complete relief”; the RTC granted the motion on February 13, 2013.
- Motions and RTC orders
- Gina filed a Motion to Dismiss ad cautelam, arguing her lack of capacity as representative of a non-existent juridical entity (Anthony’s estate), and Donald moved to declare Gina in default.
- The RTC denied both motions on August 15, 2013, and denied Gina’s motion for reconsideration on November 25, 2013.
- Court of Appeals proceedings
- Gina petitioned the CA under Rule 65, alleging grave abuse of discretion in impleading Anthony’s estate and treating her as its representative; she prayed to dismiss the complaint “insofar as it relates to the estate.”
- The CA, in its February 6, 2015 decision, set aside the RTC orders and dismissed the entire complaint; its July 14, 2015 resolution denied Donald’s motion for reconsideration.
Issues:
- Whether the CA erred in setting aside the RTC’s ruling that Anthony’s estate, represented by Gina, could be named as additional defendant.
- Whether the CA erred in dismissing the entire complaint when such relief was neither raised as an issue nor prayed for in the petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)