Case Digest (G.R. No. 232823)
Facts:
The case involves the petitioners, spouses Dan T. Paguirigan and Mary Jane Paguirigan, who operate under the name of Danny Boy Liner/Dalmatian Lines, and the respondent, Pilhino Sales Corporation. The dispute arose from an alleged transaction concerning three buses. Two civil cases were initiated by the respondent against the petitioners: Civil Case No. MC98-214 and Civil Case No. MC00-1260, both before the Regional Trial Court (RTC) of Mandaluyong City. The first case (MC98-214) was dismissed on March 26, 1999, due to the respondent's failure to file a pre-trial brief or to appear at a scheduled pre-trial conference, as indicated in the Regional Trial Court's order. The dismissal was considered final, although the court clarifies that the respondent could re-file the complaint.
On September 19, 2000, the respondent re-filed its complaint as Civil Case No. MC00-1260, which was assigned to Branch 210 of the RTC. The petitioners contested the re-filing, arguing res judica
Case Digest (G.R. No. 232823)
Facts:
# Background of the Case
- Petitioners are spouses Dan T. Paguirigan and Mary Jane Paguirigan, doing business under the name Danny Boy Liner and/or Dalmatian Lines.
- Respondent is Pilhino Sales Corporation.
- The dispute arose from an alleged transaction involving three buses.
# Civil Cases Filed
- Civil Case No. MC98-214:
- Filed by respondent Pilhino Sales Corporation against petitioners for sum of money.
- Dismissed on March 26, 1999, by the Regional Trial Court (RTC) of Mandaluyong City, Branch 214, due to respondent's failure to submit a pre-trial brief and appear at the pre-trial conference despite proper notice.
- On June 2, 2000, the court denied respondent's motion for reconsideration, stating the dismissal was final but without prejudice, allowing respondent to re-file the complaint.
- Civil Case No. MC00-1260:
- Respondent re-filed the complaint on September 19, 2000, before the RTC of Mandaluyong City, Branch 210.
- Petitioners raised defenses of res judicata and lack of jurisdiction, but the court dismissed these arguments, ruling that the earlier dismissal was not on the merits.
- Pre-trial was set for July 2, 2002.
# Procedural History
- On January 29, 2003, the trial court reversed its June 6, 2002 Order, holding that the dismissal of Civil Case No. MC98-214 was with prejudice and an adjudication on the merits, thus dismissing Civil Case No. MC00-1260 on grounds of res judicata.
- On November 18, 2003, the trial court reversed its January 29, 2003 Order, ruling that the dismissal of Civil Case No. MC98-214 was without prejudice and not an adjudication on the merits.
- On December 16, 2003, during the pre-trial conference, respondent and counsel failed to appear, leading to the dismissal of Civil Case No. MC00-1260 for failure to prosecute.
- Respondent appealed to the Court of Appeals, which set aside the dismissal and directed further proceedings. Petitioners' motion for reconsideration was denied, prompting this petition.
Issues:
- Whether Branch 210 and the Court of Appeals have jurisdiction to entertain Civil Case No. MC00-1260.
- Whether respondent's absence during the pre-trial conference on December 16, 2003, warranted the dismissal of Civil Case No. MC00-1260 for failure to prosecute.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the Court of Appeals' decision, ruling that the dismissal of Civil Case No. MC00-1260 was improper. The case was remanded for further proceedings to ensure a fair trial on the merits.
- Civil Case No. MC98-214:
- Filed by respondent Pilhino Sales Corporation against petitioners for sum of money.
- Dismissed on March 26, 1999, by the Regional Trial Court (RTC) of Mandaluyong City, Branch 214, due to respondent's failure to submit a pre-trial brief and appear at the pre-trial conference despite proper notice.
- On June 2, 2000, the court denied respondent's motion for reconsideration, stating the dismissal was final but without prejudice, allowing respondent to re-file the complaint.
- Civil Case No. MC00-1260:
- Respondent re-filed the complaint on September 19, 2000, before the RTC of Mandaluyong City, Branch 210.
- Petitioners raised defenses of res judicata and lack of jurisdiction, but the court dismissed these arguments, ruling that the earlier dismissal was not on the merits.
- Pre-trial was set for July 2, 2002.