Case Digest (G.R. No. 231485)
Facts:
In Watercraft Ventures Corporation v. Alfred Raymond Wolfe, G.R. No. 231485, September 21, 2020, the Supreme Court Second Division, Inting, J., writing for the Court, resolved a petition for review on certiorari under Rule 45.
Watercraft Ventures Corporation (petitioner), represented by its Vice President Rosario E. Ranoa, sued Alfred Raymond Wolfe (respondent) for collection of storage fees, damages, and sought a writ of preliminary attachment; the complaint arose from respondent’s use and storage of his sailboat, the Knotty Gull, at petitioner’s Subic Bay shipyard while respondent was employed by petitioner.
Petitioner alleged respondent had been charged a monthly storage fee (US$272.00) with interest for unpaid charges, and that despite using the facilities throughout his employment (hired June 1997; terminated April 7, 2002) respondent never paid storage fees. Petitioner further asserted an exclusive listing agreement in November 2000 to sell the sailboat and that respondent received invoices and a Boat Pull Out Clearance (June 29, 2002) acknowledging an unpaid balance of US$16,324.82, yet pulled out the vessel without paying. Petitioner sought recovery of storage fees running through April 2002 and later assessed large sums as outstanding.
Respondent answered with a compulsory counterclaim denying liability for storage fees. He averred a three-way partnership/arrangement (1998) with petitioner’s officers whereby no storage fees would be charged and the vessel’s repair would serve as training; he claimed he solely funded purchase and repairs, was not billed storage fees, and that petitioner used the vessel in its towing operations generating income. Respondent sought recovery of commissions and advances he made for petitioner plus damages and fees.
The Regional Trial Court (Branch 170, Malabon City) issued a writ of preliminary attachment in the interim; that writ was later annulled in a separate Supreme Court matter (Watercraft Venture Corporation v. Wolfe, G.R. No. 181721). On February 7, 2012, the RTC rendered a Partial Judgment ordering respondent to pay petitioner P807,480.00 for storage from May 1998 to April 30, 2002, legal interest, and attorney’s fees; the RTC later modified penalties to monthly charges of 2% and 4% and denied respondent’s motion for reconsideration.
Both parties appealed to the Court of Appeals (CA). On August 31, 2016, the CA reversed and set aside the RTC Partial Judgment in CA-G.R. CV No. 101702 and instead awarded respondent US$12,197.32 (in Philippine currency at the prevailing rate) for unpaid commissions and advances with interest (12% p.a. until June 30, 2013, then 6% p.a.), moral damages P200,000.00, exemplary damages P200,000.00, and attorney’s fees P100,000.00; the CA found petitioner failed to prove an agreement for storage fees or timely demand and that its own April 7, 2002 statement showed petitioner owed respondent. Petitioner’s motion for reconsideration be...(Subscriber-Only)
Issues:
- May a Rule 45 petition raise questions beyond pure questions of law when the CA and the RTC made divergent factual findings?
- May the Court of Appeals grant relief not specifically prayed for in the respondent’s answer with compulsory counterclaims?
- Was the CA correct in finding petitioner liable on the basis of a document that respondent denied?
- Was the CA correct in refusing to recognize respondent’s supposed obligation when that obligation was evidenced by a document relied upon by the CA?
- Is a 12% per annum legal interest rate applicable to the award where the judgment has not yet become final and executory?
- Did the annulment/discharge of the writ of preliminary attachment automatically render petitioner liable for moral and exemplary damages despite respondent’s failure to apply for such damages and without a hearing?
- Did respondent bear the burden of proving exemption from paying storage and berthing fees to petitioner?
- Should respondent be held liable on an obligation evidenced by a document he never denied despite having opportunity to do so?
- Is the 12% per annum legal interest applicab...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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