Title
Supreme Court
Heirs of ReiNo. Sr. vs. Court of Appeals
Case
G.R. No. 116121
Decision Date
Jul 18, 2011
Collision between jeepney and truck in 1979 led to passenger's death. Petitioners sued for damages; CA dismissed case for unpaid docket fees. SC reversed, ruling merits over technicalities, allowing fee payment, and reinstating RTC decision.

Case Digest (G.R. No. 112675)
Expanded Legal Reasoning Model

Facts:

  • Accident and parties involved
    • On June 14, 1979, at around 7:00 PM along E. Rodriguez Avenue, Quezon City, a collision occurred between a passenger jeepney and a truck.
    • Ruben Reinoso, Sr., a passenger of the jeepney, died as a result of the accident.
    • The passenger jeepney was owned by Ponciano Tapales and driven by Alejandro Santos, while the truck was owned by Jose Guballa and driven by Mariano Geronimo.
  • Initial complaint and proceedings
    • The heirs of Ruben Reinoso, represented by Ruben Reinoso Jr., filed a complaint for damages against Tapales and Guballa on November 7, 1979.
    • Jose Guballa filed a third-party complaint against Filwriters Guaranty Assurance Corporation (FGAC) under Policy No. OV-09527.
  • Regional Trial Court (RTC) Decision, March 22, 1988
    • The RTC ruled in favor of the petitioners (Reinoso heirs) and against Guballa, awarding:
      • P30,000 for death;
      • P120,000 for loss of earnings, calculated at P1,000 per month for 10 years;
      • P15,000 for mortuary, medical, funeral, and incidental expenses;
      • P50,000 moral damages;
      • P25,000 exemplary damages;
      • P15,000 litigation expenses;
      • P25,000 attorney’s fees.
Total damages of P250,000 for the death claim.
  • For damages to property of the jeepney owner Tapales, the RTC awarded:
    • P9,000 compensatory damages for loss of earnings during the jeepney’s repair;
    • P10,000 moral damages;
    • P10,000 exemplary damages;
    • P15,000 attorney’s fees.
Total damages of P44,000 for property damages.
  • Under the third-party complaint against FGAC, the RTC held FGAC liable under the insurance policy for P60,000 (P50,000 undertaking plus P10,000 attorney’s fees).
  • Court of Appeals (CA) Decision, May 20, 1994
    • The CA set aside and reversed the RTC Decision.
    • The CA dismissed the complaint on the ground of non-payment of docket fees, applying the doctrine from Manchester v. Court of Appeals.
    • The CA further ruled that prescription had set in, thus petitioners could no longer pay the required docket fees.
    • The petitioners' motion for reconsideration was denied by the CA in a resolution dated June 30, 1994.
  • Petition to the Supreme Court
    • Petitioners assailed the CA decision asserting:
      • The Manchester ruling was misapplied;
      • Specification of damages was not an issue in lower courts;
      • The case revolves on negligence and liability of respondents.
    • Petitioners argued that the Manchester doctrine on dismissal for non-payment of correct docket fees should be applied prospectively and not retroactively.
    • Petitioners maintained jurisdiction of the trial court despite fee irregularity as long as correct fees were eventually paid.
    • The case had been litigated on the merits before the RTC where non-payment of docket fees was never an issue.
  • Factual findings concerning the accident
    • The collision was caused by the truck driver’s negligence; the truck was speeding and suddenly swerved to avoid a wooden barricade under lane 1 and 2, encroaching into lane 4 where the jeepney was running.
    • The jeepney was within its right lane, moving at moderate speed (30–40 km/h).
    • Police sketch and testimonies of the jeepney driver and passengers corroborate this narrative.
    • The truck owner, Guballa, failed to rebut the presumption of negligence in hiring and supervising his driver.

Issues:

  • Whether the Court of Appeals erred in dismissing the complaint for non-payment of docket fees under the doctrine in Manchester v. Court of Appeals.
  • Whether the failure to specify the amount of damages in the complaint justifies dismissal of the petitioners’ case.
  • Whether the evidence sufficiently proved the negligence of the truck driver, and by extension, held the truck owner liable.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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