Case Digest (G.R. No. 193494) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On March 9, 1995, Lui Enterprises, Inc. (Lui) and Zuellig Pharma Corporation (Zuellig) entered into a ten-year lease over a parcel in Barrio Tigatto, Buhangin, Davao City (TCT No. T-166476). In January 2003, Philippine Bank of Communications (PBCom) informed Zuellig it had acquired the property by deed of dation and attached TCT No. 336962. Confronted with conflicting rent‐collection claims, Zuellig filed a complaint for interpleader and consignation in the RTC of Makati, depositing ₱604,024.35 and praying to consign future rentals. PBCom answered; Lui moved to dismiss, alleging lack of authority and litis pendentia due to a pending nullification case in the RTC of Davao. Lui’s motion was filed four days after the 15-day reglementary period and was denied; it was declared in default. Despite default, Lui manifested repeated orders from the Davao court directing payment to it, but took no timely steps to set aside the default. One year later, it moved to set aside the default for Case Digest (G.R. No. 193494) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Lease and title dispute
- On March 9, 1995, Lui Enterprises, Inc. (LEI) leased a parcel in Davao City to Zuellig Pharma Corporation (ZP) under TCT No. T-166476 in Eli L. Lui’s name.
- On January 10, 2003, Philippine Bank of Communications (PBC) claimed ownership under TCT No. 336962 (derived from T-166476) and demanded rent payments.
- Interpleader proceedings in Makati
- ZP filed an interpleader complaint on May 7, 2003, consigned P604,024.35, and prayed that LEI and PBC litigate their claims; LEI moved to dismiss for lack of authority and litis pendentia.
- LEI’s motion to dismiss was filed July 23, 2003, four days after the 15-day reglementary period (summons served July 4, 2003).
- Default declaration and post-default motions
- ZP and PBC moved to declare LEI in default; Makati RTC declared LEI in default on October 6, 2003; LEI did not timely seek reconsideration.
- LEI filed multiple manifestations (status quo orders from Davao RTC dated April 1, 2004 and April 18, 2005) and on October 21, 2004 moved to set aside the order of default alleging counsel’s excusable negligence.
- Trial court and appellate rulings
- Makati RTC, in its July 4, 2006 decision, barred LEI’s claim due to default, awarded P6,681,327.30 to PBC, and P50,000 attorney’s fees to ZP.
- CA dismissed LEI’s appeal on May 24, 2010 for non-compliance with Rule 44(13) requirements and affirmed the RTC in toto; denied reconsideration on August 13, 2010.
- LEI filed a petition for review on certiorari with the SC.
Issues:
- Did the CA err in dismissing LEI’s appeal for lack of required contents in the appellant’s brief?
- Did the Makati RTC err in denying LEI’s motion to set aside the order of default?
- Did the pending nullification of deed of dation in payment case in Davao bar the interpleader case in Makati (litis pendentia)?
- Was ZP entitled to attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)