Case Digest (G.R. No. L-31600) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Anita Mangila v. Court of Appeals and Loreta Guina (G.R. No. 125027, August 12, 2002), petitioner Anita Mangila, trading as Seafoods Products, engaged private respondent Loreta Guina—sole proprietor of Air Swift International—to forward seafood shipments to Guam in January 1988. The parties agreed on cash-on-delivery terms, with respondent’s invoice prescribing 18% interest per annum on overdue accounts and 25% attorney’s fees plus costs in case of litigation. Mangila paid the first consignment but failed to settle charges on three subsequent shipments (March 17, 24 and 31, 1988) amounting to P109,376.95. After demands went unheeded, Guina filed Civil Case No. 5875 in the Regional Trial Court (RTC) of Pasay City on June 10, 1988, but summons could not be served because Mangila had left the Philippines for Guam.Concluding that Mangila’s departure was intended to defraud creditors, respondent secured a writ of preliminary attachment on September 27, 1988, which was implemente
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Case Digest (G.R. No. L-31600) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contract
- Anita Mangila (petitioner) is an exporter of seafoods under the trade name Seafoods Products.
- Loreta Guina (private respondent) is president and general manager of Air Swift International, a freight‐forwarding sole proprietorship.
- In January 1988, petitioner engaged respondent to ship crabs, prawns and assorted fishes to Guam, agreeing to pay cash on delivery; respondent’s invoice provided for 18% annual interest on overdue accounts and 25% attorney’s fees plus costs in case of suit.
- Nonpayment and Attachment
- Petitioner paid the first shipment within seven days but defaulted on three subsequent shipments (March 17, 24 and 31, 1988), owing P109,376.95.
- Private respondent made repeated demands; when payment was not forthcoming, she filed Civil Case No. 5875 on June 10, 1988 in the RTC of Pasay City for collection.
- Service, Attachment and Default Proceedings
- Summons could not be served in August 1988; petitioner was allegedly abroad. On September 13, 1988, respondent moved for preliminary attachment on grounds of intent to defraud creditors.
- RTC Branch 108 issued an Order of Preliminary Attachment on September 26 and the Writ on September 27, 1988; levy was made October 28, 1988 in Pampanga without prior summons.
- Petitioner filed an Urgent Motion to Discharge Attachment (November 7, 1988) arguing lack of jurisdiction. RTC granted discharge upon counter‐bond (January 13, 1989) but did not rule on jurisdiction or attachment validity. Alias summons issued January 19 and served January 26, 1989.
- Petitioner moved to dismiss for improper venue; RTC denied it. Pre‐trial on July 18, 1989 was reset to August 24, 1989. At pre‐trial only respondent’s counsel appeared; RTC terminated pre‐trial and allowed ex parte evidence. Petitioner’s motions for reconsideration and omnibus motion were denied.
- On November 10, 1989, RTC rendered judgment ordering petitioner to pay P109,376.95 plus 18% per annum, 25% attorney’s fees and costs. Execution pending appeal was denied.
- Court of Appeals and Supreme Court Petition
- On December 15, 1995, the Court of Appeals (G.R. CV No. 25119) affirmed the RTC decision, upholding attachment, venue, default and damages. Motion for reconsideration was denied on May 20, 1996.
- Petitioner filed a petition for review under Rule 45 before the Supreme Court, challenging attachment validity, default declaration, venue and the monetary award.
Issues:
- Whether the writ of preliminary attachment was improperly issued and served, rendering it void.
- Whether the declaration of petitioner’s default was valid.
- Whether venue in the RTC of Pasay City was improper.
- Whether the trial court erred in holding petitioner liable for P109,376.95 plus attorney’s fees and costs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)