Case Digest (G.R. No. 216569)
Facts:
Philippine National Construction Corporation v. Superlines Transportation Co., Inc., G.R. No. 216569, June 03, 2019, Supreme Court Second Division, Reyes, J. Jr., writing for the Court. The petition challenges the Court of Appeals Decision dated May 30, 2014 and Resolution dated January 13, 2015 in CA-G.R. CV No. 95429 that affirmed with modification the Regional Trial Court of Gumaca, Quezon, Branch 62 (RTC) decision.One of Superlines Transportation Co., Inc.’s buses crashed into the radio room of Philippine National Construction Corporation (PNCC). The bus was turned over to the Alabang Traffic Bureau for investigation; Traffic Investigator Patrolman Cesar Lopera (Lopera) ordered the bus to be towed, and because of limited space it was stored in PNCC’s compound. PNCC’s head of traffic control and security, Pedro Balubal, refused Superlines’ requests for release and demanded P40,000 or equivalent collateral as estimated reconstruction cost of the radio room. Superlines filed a complaint for replevin with damages against PNCC and Balubal in the RTC; PNCC and Balubal counterclaimed for actual and exemplary damages, attorney’s fees and litigation expenses.
In a December 9, 1997 RTC decision, the trial court dismissed Superlines’ complaint and ordered Superlines to pay PNCC P40,320.00. On appeal, the Court of Appeals held that PNCC’s storage was a deposit and that custody remained with Lopera, concluding the action should have been brought against the police. This Court, in G.R. No. 169596 (Superlines Transportation Co., Inc. v. Philippine National Construction Company), reversed the CA: it granted Superlines’ prayer for recovery of possession, deemed the seizure a violation of constitutional rights, and remanded to the RTC directing that Lopera and other responsible police officers be impleaded as indispensable parties should Superlines pursue damages.
Following the remand, Superlines filed an amended complaint impleading Lopera; Lopera answered. Attempts to execute this Court’s decision were hampered by uncertain whereabouts of the bus. At some point Lopera was dropped as a party in the remanded RTC proceedings. In a May 12, 2010 decision, the RTC found PNCC and Balubal liable for the cost of the bus (P2,036,500.00), lost/unearned income (P33,750,000.00 for 1991–2006), exemplary damages (P5,000,000.00), and attorney’s fees (P300,000.00). PNCC appealed to the Court of Appeals in CA-G.R. CV No. 95429.
The CA, in a Decision dated May 30, 2014 (authored by A.J. Elihu A. Ybanez, with AJs Japar B. Dimaampao and Carmelita S. Manahan concurring), affirmed the RTC decision but reduced exemp...(Subscriber-Only)
Issues:
- Did the dropping of Patrolman Cesar Lopera as a defendant violate this Court’s directive in G.R. No. 169596 that Lopera and other responsible police officers be impleaded as indispensable parties in Superlines’ claim...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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