Case Digest (G.R. No. 134888)
Facts:
Ram's Studio and Photographic Equipment, Inc. v. Court of Appeals, Spouses Castro Jose Rivera and Gina Cynthia Hernal Rivera, G.R. No. 134888, December 01, 2000, Supreme Court Second Division, Bellosillo, J., writing for the Court.On 8 November 1994 Gina Cynthia Hernal contracted Ram's Studio and Photographic Equipment, Inc. (RAM's) to provide video coverage for her wedding scheduled for 27 January 1995. The videographers arrived late, delaying the bride's march to the altar, and the delivered videotape showed a brownish-black screen for the first thirty minutes; RAM’s later offered to re‑shoot the damaged portion at its expense, which the spouses rejected.
On 5 July 1995 the spouses filed a complaint for damages against RAM's before the Regional Trial Court (RTC) of Muntinlupa City; they amended their complaint on 23 August 1995. RAM’s twice sought extensions to answer but failed to file within the extended periods and, on motion of the spouses, was declared in default on 22 January 1996. After plaintiffs presented evidence ex parte, the RTC rendered a default judgment (dispositive portion quoted below) ordering substantial actual, moral, exemplary damages, attorney’s fees and costs.
Counsel for RAM’s received a copy of the RTC decision on 10 April 1996; RAM’s itself received a copy on 11 April 1996. By registered mail RAM’s new counsel filed a motion for new trial on 26 April 1996—one day after counsel of record had received notice. The spouses moved for issuance of execution and to deny the belated motion for new trial. The RTC initially granted execution on 11 October 1996 and denied reconsideration on 13 January 1997, issuing a writ of execution on 14 January 1997.
Subsequently, on 6 March 1997 the RTC reconsidered and granted RAM’s motion for new trial, reasoning that counting from the defendant’s receipt (11 April) the motion was within the reglementary period, and even if late as to former counsel it was within the period for a petition for relief under Rule 38, Section 2. The spouses moved for reconsideration of that grant; the RTC denied reconsideration on 24 June 1997. The spouses elevated the matter, and on 1 October 1997 the Supreme Court referred the case to the Court of Appeals.
On 20 February 1998 the Court of Appeals set aside the RTC orders dated 6 March 1997 and 24 June 1997, holding that the motion for new trial was filed one day late because notice to the counsel of record (10 April 1996) starts the running of the fifteen‑day period, thus rendering the RTC judgment final and executory. RAM’s moved for reconsideration in the Court of Appeals, which wa...(Pro-only)
Issues:
- Was RAM’s motion for new trial timely filed?
- If timely, did RAM’s establish grounds warranting a new trial (extrinsic fraud or other valid excuse to set aside the default j...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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