Facts:

This case involves a petition for review on certiorari under Rule 65 of the Revised Rules of Court filed by Victory Liner, Inc. (petitioner) against the Court of Appeals and Viron Transportation Company (respondents). The events leading to this petition began on June 22, 1994, when Viron Transportation Company filed a complaint for damages against Victory Liner, Inc. due to a vehicular accident that occurred on May 6, 1994. This case, designated as Civil Case No. 144592-CV, was brought before the Metropolitan Trial Court of Manila, Branch 4.

On March 27, 1995, Victory Liner filed its Answer to the complaint. A pre-trial conference was initially set for April 27, 1995, but was rescheduled to May 23, 1995, at 2:00 PM following a motion from the petitioner. On that date, only Atty. Atilano B. Lim appeared for the petitioner; there was no representative from Victory Liner present. Counsel arrived late, after the court had adjourned, leading the court to declare Victory Liner in defa

...

Facts:

1. Parties Involved:

   • Petitioner: Victory Liner, Inc.
   • Respondents: Court of Appeals and Viron Transportation Company.

2. Nature of the Case:

   • Viron Transportation Company filed a complaint for damages against Victory Liner, Inc., arising from a vehicular accident on May 6, 1994. The case was docketed as Civil Case No. 144592-CV before the Metropolitan Trial Court (MeTC) of Manila, Branch 4.

3. Procedural Background:

   • Victory Liner filed its Answer on March 27, 1995.
   • Pre-trial was initially scheduled for April 27, 1995, but was reset to May 23, 1995, at 2:00 PM, upon Victory Liner's motion.
   • On May 23, 1995, Victory Liner's counsel, Atty. Atilano B. Lim, arrived late at the sala of Judge Leonardo P. Reyes, after the court had adjourned. Victory Liner was declared in default, and Viron Transportation was allowed to present evidence ex parte.

4. Motion to Lift Order of Default:

   • Victory Liner filed a Motion to Lift Order of Default on May 24, 1995, citing heavy traffic and counsel's unfamiliarity with the court's location as reasons for the delay.
   • The MeTC denied the motion on May 26, 1995, stating that heavy traffic and unfamiliarity with the court were unacceptable justifications. The court also noted the absence of Victory Liner's representative and the lack of a special power of attorney authorizing Atty. Lim to represent the company.

5. Motion for Reconsideration:

   • Victory Liner filed a Motion for Reconsideration on June 7, 1995, which was denied on June 9, 1995.

6. Appeal to the Court of Appeals:

   • Victory Liner filed a Petition for Certiorari with the Court of Appeals, which dismissed the petition on May 22, 1996, affirming the MeTC's Orders.

7. Petition to the Supreme Court:

   • Victory Liner elevated the case to the Supreme Court, raising issues of due process and grave abuse of discretion by the lower courts.

Issue:

1. Whether the Court of Appeals acted with grave abuse of discretion in affirming the MeTC's Orders declaring Victory Liner in default and denying its Motion for Reconsideration.
2. Whether the Court of Appeals erred in adopting the MeTC's presumption that Victory Liner's counsel lacked special authority to represent the company during the pre-trial.

---

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)