G.R. No. 163186 - Aguila vs. Baldovizo

Case Summary (G.R. No. 163186)

Summary of Factual Background

On April 19, 1993 at about 11:30 a.m., a van (Plate No. TER-883) registered in the name of Danilo D. Reyes and driven by Marlun Lisbos sideswiped pedestrian Fausto T. Baldovizo while Fausto was crossing EDSA near Monumento Market. Fausto suffered injuries, was hospitalized at Manila Central University Hospital, and subsequently died on July 6, 1993. Criminal charges for reckless imprudence resulting in homicide were filed against Lisbos before the Metropolitan Trial Court of Caloocan City. Separately, the Baldovizos filed a civil complaint for damages against Lisbos, Reyes, Aguila, and Times Surety and Insurance Company before the Regional Trial Court (RTC) of Quezon City, Branch 225.

Pleadings, Defenses, and Trial Court Course

Summons were served on all defendants except Lisbos (whose whereabouts were reported unknown). Aguila asserted that the pedestrian disregarded traffic rules, that he exercised due diligence in selecting Lisbos as driver, and that he provided assistance during hospitalization. Reyes denied ownership despite registration in his name, claiming Aguila was the actual possessor/operator. Times Surety and Insurance Company was declared in default for failure to file an Answer. Petitioners failed to appear for the December 1, 1999 hearing and were considered to have waived their right to present evidence. Trial proceeded and the RTC rendered judgment on March 7, 2000.

Trial Court Judgment and Monetary Awards

The RTC judgment of March 7, 2000 found in favor of the Baldovizos and ordered defendants (Aguila, Reyes, Lisbos, and Times Surety and Insurance Co., Inc.) to pay jointly and severally the following amounts: P43,800.00 (loss of earning capacity); P110,700.00 (medical and hospital bills); P15,800.07 (post-confinement medicine expenses); P50,000.00 (death indemnity); P50,000.00 (moral damages); and P20,000.00 (exemplary damages), plus costs of suit.

Post-Judgment Motions and Amended Decision

Petitioners Aguila and Reyes filed a petition for relief from judgment on May 4, 2000, which the trial court denied in a Resolution dated November 20, 2000. The Baldovizos sought issuance of a writ of execution, which the trial court granted on May 21, 2001; the trial court denied petitioners’ subsequent motions. On August 13, 2001, the trial court issued an Amended Decision that struck the name of Marlun Lisbos from the dispositive portion of the March 7, 2000 Decision, stating his inclusion had been inadvertent, and otherwise denied motions for reconsideration.

Court of Appeals Ruling and Procedural Posture

Aguila and Reyes appealed the Amended Decision to the Court of Appeals (CA). The CA denied the appeal as improper because the original March 7, 2000 Decision had become final and executory for lack of timely appeal or proper motions within the reglementary period; the Amended Decision did not revive or create a new period to appeal. The CA also sustained the Amended Decision insofar as it deleted Lisbos’ name from the dispositive portion, and it denied petitioners’ motion for reconsideration. Petitioners elevated the case to the Supreme Court.

Legal Issue Presented to the Supreme Court

The sole issue before the Supreme Court was whether petitioners retained a right to appeal the Amended Decision dated August 13, 2001 after the original March 7, 2000 Decision had already become final and executory.

Petitioners’ Contentions in Brief

Petitioners argued that the Amended Decision superseded the original Decision and effectively increased their liabilities by excluding Lisbos from the persons ordered to pay, thereby justifying an appeal from the Amended Decision. They further contended that the trial court had approved their notice of appeal and invoked the doctrine of substantial justice to request consideration of the merits and relief from liability.

Supreme Court’s Analysis on Finality and the Immutability of Judgments

The Court applied Rule 36, Section 2 of the Rules of Court: a judgment becomes final and executory if no appeal, motion for new trial, or motion for reconsideration is filed within the time prescribed; the court has no jurisdiction to amend a judgment after finality except in narrow circumstances (clerical errors, nunc pro tunc entries that cause no prejudice, or void judgments). The Court emphasized the principle of immutability of final judgments and cited controlling jurisprudence to show that once final, a judgment cannot be altered absent the recognized exceptions.

On the Petition for Relief from Judgment and Tolling of the Appeal Period

The Supreme Court found that petitioners’ filing of a petition for relief from judgment on May 4, 2000 was an improper and extraordinary remedy where other regular remedies existed (appeal, motion for reconsideration, or motion for new trial). Because the petition for relief from judgment was not the correct remedy to invoke during the reglementary period, it did not toll the running of the period for appeal or other remedies. Consequently, the March 7, 2000 Decision became final and executory when the prescribed period lapsed.

Validity of the Amended Decision and Liability of Petitioners

Because the March 7, 2000 Decision was final and executory at the time the Amended Decision was entered, any amendment that substantially affected the final judgment was void for lack of jurisdiction. The Court declared the Amended Decision of August 13, 2001 null and void to the extent it altered the final judgment. The Court also observed that striking the driver’s name from the dispositive portion was unnecessary to impose liability on pe

Case Syllabus (G.R. No. 163186)

Procedural Posture

Petition for review to the Supreme Court seeking reversal of the Court of Appeals Decision dated June 30, 2003 (CA-G.R. CV No. 73321) and its Resolution dated April 1, 2004.
Court of Appeals had affirmed the Regional Trial Court (RTC), Quezon City, Branch 225, Amended Decision dated August 13, 2001, which had found petitioners jointly and severally liable for damages arising from the death of Fausto T. Baldovizo.
Supreme Court consideration limited to whether petitioners had the right to appeal the Amended Decision after the original March 7, 2000 Decision had become final and executory.

Parties

Petitioners: Emerlito F. Aguila and Danilo D. Reyes.
Respondents/Plaintiffs below: Carmen R. Baldovizo (wife of the deceased), Edgar R. Baldovizo and Carmelo R. Baldovizo (sons of the deceased).
Other named defendants below: Marlun G. Lisbos (driver), Times Surety and Insurance Company (insurer of the van).

Facts

Date/time/location of incident: April 19, 1993, at about 11:30 a.m., along Epifanio de los Santos Avenue (EDSA) in Caloocan City, in front of the Monumento Market.
Vehicle involved: a van with Plate No. TER-883, registered under the name of Danilo D. Reyes.
Driver at the time: Marlun Lisbos was driving the van.
Nature of accident: the van sideswiped Fausto T. Baldovizo while he was walking/crossing along the pedestrian lane in front of Monumento Market; Fausto fell, suffered injuries, was hospitalized at Manila Central University Hospital, and subsequently died on July 6, 1993.
Criminal charge: On May 20, 1994, Marlun Lisbos was charged with reckless imprudence resulting in homicide at the Metropolitan Trial Court of Caloocan City, Branch 52.
Civil complaint: On September 24, 1994, Carmen, Edgar and Carmelo Baldovizo filed a complaint for damages before RTC, Quezon City, Branch 225, against Marlun Lisbos, Danilo D. Reyes, Emerlito F. Aguila (actual operator and possessor of the van), and Times Surety and Insurance Company (insurer under third-party liability insurance).
Service of summons: Summons served on defendants except Marlun Lisbos, whose whereabouts were unknown according to the Sheriff’s Report.

Defenses and Pleadings Below

Emerlito F. Aguila’s Answer: alleged Fausto disregarded traffic rules when crossing EDSA; Aguila exercised due diligence in selecting Lisbos as driver; Aguila provided assistance/support during Fausto’s hospitalization.
Danilo D. Reyes’ Answer: denied ownership of the van; although registered in his name, Reyes claimed Aguila was its actual possessor and operator and thus Reyes asserted he could not be liable for damages.
Times Surety and Insurance Company: declared in default for failure to file an Answer.
Petitioners’ conduct in trial: petitioners were considered to have waived their right to present evidence for failure to appear at the December 1, 1999 hearing.

Trial Court Decision (March 7, 2000)

Trial court rendered judgment on March 7, 2000 in favor of the Baldovizos and against defendants Emerlito F. Aguila, Danilo Reyes, Marlun G. Lisbos and Times Surety and Insurance Co., Inc., ordering them jointly and severally to pay:
- P43,800.00 for loss of earning capacity
- P110,700.00 for medical expenses and hospital bills
- P15,800.07 for medicine expenses incurred after confinement
- P50,000.00 as death indemnity
- P50,000.00 as moral damages
- P20,000.00 as exemplary damages
- Costs of suit
Decretal form: judgment explicitly ordered joint and several liability as to the named defendants.

Post-Judgment Motions and Proceedings in the RTC

Petitioners Aguila and Reyes filed a petition for relief from judgment on May 4, 2000; the trial court denied it in a Resolution dated November 20, 2000.
The Baldovizos moved for issuance of writ of execution after judgment attained finality; petitioners filed a motion for reconsideration of the November 20, 2000 Resolution and a motion to dismiss for lack of jurisdiction, alleging defective certification against forum shopping.
On May 21, 2001, the trial court granted the writ of execution and denied petitioners’ motions.
Petitioners filed additional motions for reconsideration and informed the trial court of intention to appeal the November 20, 2000 Resolution.
On August 13, 2001, the trial court denied the second motion for reconsideration and the motion for reconsideration of the writ order, and resolved to strike off the name of Marlun Lisbos in the dispositive portion of the March 7, 2000 Decision for having been inadvertently included; the court issued an Amended Decision dated August 13, 2001 deleting Lisbos from the dispositive portion.

Appeal to the Court of Appeals and Its Ruling

Petitioners Aguila and Reyes appealed the Amended Decision to the Court of Appeals.
Court of Appeals denied the appeal as improper, holding that petitioners had lost their right to appeal because no appeal from the March 7, 2000 Decision had been filed within the regl