G.R. No. 113564 - Dino vs. Court of Appeals

A laboratory accident occurred during an Organic Chemistry class at Saint Louis University (SLU), Baguio City.
During an experiment on Hydrocarbons-Alkanes Methane, chemicals (anhydrous sodium acetate and barium hydroxide) burst from a hard test tube.
The expelled chemicals struck student Winston Joseph Z. Cordero, resulting in his right eye becoming totally blind and significant discomfort with his left eye.
Although the textbook recommended the use of goggles, no eye protection was provided, and students were instructed to proceed without them.

After the accident, Winston was promptly brought to SLU Hospital where he remained for two days.
Due to perceived inadequacies in the hospital, his parents (Lucio and Evelyn Cordero) arranged his transfer to St. Luke’s Medical Center in Manila, where he received further treatment for five days.
Despite medical intervention, Winston’s right eye was permanently damaged, eventually leading to an operation on 5 October 1995 for the implantation of an artificial right eye.

On 24 January 1996, the Corderos filed a complaint for damages against SLU, its President Fr. Joseph Van Den Dailen, the Chairman of the Chemical Engineering Department Engr. Josephine Aries Dulay, the Dean Eufracio de los Reyes, and the Instructor, Engr. Christine O. Bautista.
The complaint was based on allegations of gross negligence resulting in the infliction of injuries on Winston during the laboratory experiment.

After a full-blown trial at Branch 24 of the Regional Trial Court (RTC) of Echague, Isabela, a judgment was rendered on 30 May 1998.
The judgment found SLU and Engr. Bautista liable for gross negligence, ordering them to pay detailed amounts for medical treatment, loss of the right eye, injury to the left eye, artificial eye cost, hospitalization, doctor’s fees, moral damages, exemplary damages, and attorney’s fees.
The judgment accordingly absolved other SLU officers and dismissed the complaint regarding the Cordero spouses.

On 25 June 1998, the Corderos filed a Motion for Reconsideration requesting an increase in the awarded damages and inclusion of awards for the spouses.
On the same day, petitioners (SLU and Engr. Bautista) filed a Notice of Appeal, objecting to the Motion for Reconsideration as being filed out of time.
The trial court, through a subsequent judge, granted the motion for reconsideration on 17 December 1998, increasing exemplary damages to P1 million and awarding additional moral damages to the spouses.
A second Notice of Appeal was filed by petitioners on 6 January 1999, contesting the modified decision.

Petitioners filed a Motion to Admit Docket and Filing Fees in the Court of Appeals on 23 February 1999, accompanied by postal money orders dated 19 February 1999.
Petitioners’ counsel explained the delay by stating a lack of knowledge regarding the amount and proper payment procedure due to the distance between Baguio City and Echague, Isabela.
The Court of Appeals, in a Resolution dated 21 September 1999, denied the motion to admit docket fees and reaffirmed the dismissal based on noncompliance with the Rules of Court.

The gross negligence of their former counsel, leading to the late payment of docket fees, should not bind them and thus results in a denial of due process.
Procedural technicalities should not override substantial justice, especially when a meritorious defense exists.

They cited the case Amil v. Court of Appeals to argue that an exception should be made when counsel’s gross negligence causes forfeiture of the day in court.

Respondents argued that the Rules of Court mandate strict compliance with the payment of docket fees as a condition for the perfection of an appeal.
They maintained that the alleged negligence of counsel, regardless of its severity, is binding on the client.
The legal basis for the dismissal was anchored on Section 4, Rule 41 of the 1997 Rules of Civil Procedure, which explicitly requires payment of docket fees within the prescribed reglementary period.

Whether the dismissal of the petitioners’ appeal due to the failure to timely pay the docket fees was proper under Section 4, Rule 41 of the 1997 Rules of Civil Procedure.
Whether the petitioners’ claim that the gross negligence of their former counsel should relieve them from the consequences of nonpayment of docket fees is legally tenable.
Whether the strict procedural requirement for fee payment can be relaxed to accommodate a case that allegedly has a meritorious defense, thereby preventing a denial of due process.