Case Digest (G.R. No. 182075)
Facts:
The Philippine American Life & General Insurance Company v. Joseph Enario, G.R. No. 182075, September 15, 2010, First Division, Perez, J., writing for the Court. Petitioner is The Philippine American Life & General Insurance Company (Philamlife); respondent is Joseph Enario, a former Philamlife agent and unit manager.Enario was appointed agent on 12 November 1991 and resigned in February 2000. After resignation, Philamlife claimed he had an outstanding debit balance of approximately P1,237,336.20 under the Revised Agency Contract and sent demand letters; Enario requested time to reconcile his accounts but negotiations failed. Philamlife filed a complaint for collection in the Regional Trial Court (RTC) of Manila on 22 June 2001.
At the RTC, pre-trial conferences were set repeatedly. Notices show pre-trial dates on 3 and 17 December 2002, then on 8 May, 3 June and 1 July 2003 after efforts at settlement. Enario filed motions for postponement (citing schedule conflicts and medical reasons) but many were received by the court late. On 3 June 2003 Enario did not appear; the RTC issued an order noting his nonappearance, granted Philamlife leave to present evidence on 1 July (and later ordered ex parte presentation), and the court treated Enario as in default for failing to appear repeatedly. Philamlife presented formal offers of evidence, including statements of account and sales vouchers.
On 24 November 2003 the RTC denied Enario’s motion for reconsideration of the default order and admitted Philamlife’s evidence. On 24 February 2004 the RTC rendered judgment for Philamlife in the amount of P1,122,781.66, plus attorney’s fees and costs. Enario secured relief from the Court of Appeals by filing a petition for certiorari under Rule 65; on 28 September 2007 the Court of Appeals vacated the RTC’s June and November 2003 orders and the February 24, 2004 decision, and remanded the case for pre-trial and other proceedings, reasoning that Section 5, Rule 18 of the Rules of Court permits ex parte presentation and judgment but does not authorize a declaration of default for failure to appear at pre-trial. Philamlife’s motion for reconsideration before the CA was denied on 6 March 2008.
Philamlife then filed a petition for certiorari with the Supreme Court assailing the CA...(Pro-only)
Issues:
- Did the RTC err in declaring the defendant in default and allowing the plaintiff to present evidence ex parte because of the defendant’s failure to appear at pre-trial?
- Was the defendant’s right to procedural due process violated by the RTC’s allowance of ex parte presentation and by the rendition of judgment based on plaintiff’s evidence?
- Was the RTC’s award for the outstanding debit balanc...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)