Case Digest (G.R. No. 141857)
Facts:
This case, Rodson Philippines, Inc. et al. vs. Court of Appeals and Eastar Resources (Asia) Corporation, G.R. No. 141857, was decided on June 9, 2004, by the Second Division of the Supreme Court of the Philippines. The petitioners include Rodson Philippines, Inc., Eurasia Heavy Industries, Inc., Autographics, Inc., and Peter Y. Rodriguez, while the respondents are the Court of Appeals and Eastar Resources (Asia) Corporation. The originating case was filed on July 19, 1990, in the Regional Trial Court (RTC) of Cebu City, Branch 7, presided over by Judge Generoso A. Juaban as Civil Case No. CEB-9224. The petitioners filed a complaint for damages against Eastar, which subsequently denied the claims and filed a compulsory counterclaim for P29,000,000.
A full-blown trial began after initial pre-trial proceedings did not lead to an amicable settlement. The petitioners presented two witnesses, and on September 3, 1993, they filed a formal offer of evidence, subsequently resting their
Case Digest (G.R. No. 141857)
Facts:
- Background of the Case
- Petitioners – Rodson Philippines, Inc., Eurasia Heavy Industries, Inc., Autographics, Inc. and Peter Y. Rodriguez – filed a Complaint for damages against respondent Eastar Resources (Asia) Corporation before the RTC of Cebu City, Branch 7, in Civil Case No. CEB-9224.
- The respondent denied the allegations and interposed a compulsory counterclaim amounting to P29,000,000.
- The case proceeded to a full trial on the merits following the completion of the requisite pre-trial and failure of the parties to settle amicably.
- Presentation of Evidence and Procedural Developments
- Petitioners presented evidence, including the testimony of Peter Y. Rodriguez and Yolanda Lua, and submitted their formal offer of evidence on September 3, 1993.
- The respondent presented one witness, Mary C. Maquilan.
- On March 29, 1994, the respondent requested additional time to file its formal offer of evidence, which was granted for fifteen (15) days. Simultaneously, petitioners were allowed a period of ten (10) days to file their comments or objection thereto.
- At a later hearing, petitioners declared their intention to present rebuttal evidence and requested to recall Maquilan for further cross-examination, arguing dissatisfaction with the previous cross-examination conducted by their former counsel.
- The trial court granted a motion extension, giving petitioners fifteen (15) days to file the necessary motion and ten (10) days for the respondent’s comment.
- On June 24, 1994, petitioners formally filed their motion to recall Maquilan for additional cross-examination.
- Changes in Court and Handling of the Motion
- Amid the pendency of the motion, Judge Juaban retired and Acting Presiding Judge Andres C. Garalza, Jr. issued an order for the respondent to file its written comment within seven (7) days.
- Subsequently, Judge Martin A. Ocampo was appointed as presiding judge of the RTC, Branch 7.
- During the hearing on March 26, 1996, petitioners pointed out that they had not filed a comment on the respondent’s formal offer of evidence due to the pending motion to recall the witness.
- The trial court declared that the offer of evidence had been rendered premature because of the unresolved motion, effectively suspending its resolution.
- Subsequent Developments in Evidence Filing and Court Orders
- Despite the pending motion to recall Maquilan, petitioners failed to file their comment on the respondent’s formal offer.
- On April 1, 1996, a subpoena ad testificandum was issued requiring Maquilan to appear as a hostile rebuttal witness, prompting the respondent to file an urgent motion to quash the subpoena on the ground of distance.
- The trial court raised doubts about compelling Maquilan, a resident of Quezon City, to appear given her location relative to the trial venue.
- Petitioners then filed a motion to inhibit the judge and have the case re-raffled, aiming to safeguard their interests.
- On August 19, 1996, Judge Ocampo inhibited himself, and the case was subsequently re-raffled to RTC of Cebu City, Branch 11, presided by Judge Dicdican.
- After review, the new trial court discovered that petitioners’ motion to recall had been denied, their comment on the respondent’s evidence remained unfiled, and the formal offer was unresolved.
- On July 17, 1997, the trial court admitted the respondent’s documentary evidence.
- The trial court then rescheduled the presentation of petitioners’ rebuttal evidence to August 27, 1997.
- Petitioners filed a Motion to Defer the August 27 hearing on August 25, 1997, seeking to file written objections to the formal offer, but the motion was denied as the ten-day filing period had expired.
- A subsequent motion for reconsideration of the denial was also dismissed.
- Petitioners elevated the issue by filing a petition for certiorari and prohibition with the Court of Appeals, arguing that their right to due process had been gravely violated.
Issues:
- Whether the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction when it:
- Resolved the respondent’s formal offer of evidence and admitted the documentary evidence before petitioners could file their objection.
- Denied petitioners the opportunity to file their comment on the respondent’s voluminous offer of evidence, allegedly resulting in a miscarriage of justice.
- Whether the Court of Appeals had the authority to disregard Section 6 of Rule 65 of the 1997 Rules of Civil Procedure to favor the respondent, essentially causing a procedural disadvantage to the petitioners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)