Case Digest (G.R. No. 155619)
Facts:
In Alberto T. Lasala v. National Food Authority, G.R. No. 171582, decided August 19, 2015 under the 1987 Constitution, petitioner Alberto T. Lasala (formerly doing business as PSF Security Agency) supplied security guards to the National Food Authority (NFA). In 1994, Lasala’s deployed guards filed an NLRC complaint seeking unpaid wages and benefits, and the NLRC held Lasala and NFA solidarily liable for P383,572.90, leading to garnishment of NFA bank deposits. Believing it had no liability, the NFA sued Lasala in the Regional Trial Court (RTC) of Quezon City, Branch 220, for sums and damages and sought a writ of preliminary attachment. Lasala answered with a counterclaim for moral damages (P1 million), exemplary damages (P500,000), attorney’s fees (P300,000), compensatory damages (P250,000), and unpaid wage differentials (P1.5 million), totaling P3.55 million, and opposed the attachment. The RTC initially issued the writ, later nullified by the Court of Appeals (CA). On May 2,Case Digest (G.R. No. 155619)
Facts:
- Parties and Background
- Petitioner Alberto T. Lasala, through PSF Security Agency, provided security services to National Food Authority (NFA).
- Lasala’s employees filed an NLRC complaint (1994) for underpaid wages; NLRC held Lasala and NFA solidarily liable and garnished NFA funds.
- Proceedings in RTC
- NFA sued Lasala in RTC Quezon City Branch 220 for sum of money with damages and sought preliminary attachment; Lasala answered with a P3,550,000 counterclaim for various damages and unpaid wage differential.
- First counsel (Atty. Mendoza) failed to present NFA’s evidence—inadvertently dismissing NFA’s complaint—but Lasala’s counterclaim survived; second counsel (Atty. Cahucom) presented no contrary evidence or cross-examination.
- RTC granted Lasala’s counterclaim for P52,788,970.50 (far above prayed amount), including compensatory, moral, exemplary damages, litigation expenses, wage adjustment plus high interest.
- Post-judgment Events
- NFA failed to appeal; petition for relief from judgment (based on excusable negligence) was denied.
- NFA management’s legal audit uncovered counsel’s gross mishandling; NFA filed in CA a petition (and amended petition) for annulment of judgment on grounds of extrinsic fraud and lack of jurisdiction.
- Court of Appeals annulled the RTC decision, reasoning no concrete evidence supported Lasala’s counterclaim and thus the RTC acted without jurisdiction.
Issues:
- Res judicata and availability of petition for annulment
- Whether NFA’s prior petition for relief bars its petition for annulment of judgment.
- Whether extrinsic fraud ground was waived for not being raised in the petition for relief.
- Proper grounds and scope of Rule 47 annulment
- Whether the CA erred in expanding “lack of jurisdiction” to include grave abuse of discretion.
- Whether counsel’s negligence amounts to extrinsic fraud.
- Whether Lasala’s wage adjustment counterclaim was compulsory (no docket fees) or permissive (requiring fees and subject to prescription).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)