Case Summary (G.R. No. L-25134)
Relevant Ordinances
On February 17, 1949, the City Council of Bacolod enacted Ordinance No. 66, imposing a bottling tax on manufacturers of soft drinks, which was later amended by Ordinance No. 150 in 1959, adjusting the tax rate from P0.01 to P0.03 per case. The ordinances provided for a 2% monthly surcharge on delinquent payments, capped at 24% for a year.
Initial Lawsuit and Judgment
The City of Bacolod initially filed a lawsuit (Civil Case No. 5693) in March 1960 to recover unpaid bottling taxes amounting to P26,306.54. The court ruled in favor of the City, ordering San Miguel Brewery to comply with the amended tax provisions. Subsequently, the ruling was affirmed on appeal, establishing the constitutionality and validity of the ordinances.
Subsequent Action for Surcharges
After the initial judgment had become final, the City sought to include surcharges in the execution of that decision, which was denied. As a result, the City initiated a second lawsuit (Civil Case No. 7355) seeking recovery of the surcharges totaling P36,519.10 arising from the previously unpaid bottling taxes.
Appellant's Defense
San Miguel Brewery moved to dismiss the second action, arguing that it was barred by the prior judgement and that the City had improperly split its cause of action into separate lawsuits. The Brewery maintained that since the surcharges were not included in the first complaint, they were precluded from recovery in the subsequent action.
Rulings on the Motion to Dismiss and Trial Court's Decision
The trial court denied the Brewery's motion to dismiss, leading to a judgment ordering the Brewery to pay the surcharges. The Brewery appealed this decision, claiming that it was erroneous for the trial court to hold them liable for surcharges previously omitted from the initial lawsuit.
Legal Principles of Cause of Action Splitting
The Supreme Court upheld the principle that a party may not split a single cause of action into multiple lawsuits as per Section 3 and 4 of Rule 2 of the Rules of Court, which prohibits the submission of separate complaints for different parts of a single cause of action.
...continue readingCase Syllabus (G.R. No. L-25134)
Case Overview
- The case arises from an appeal by San Miguel Brewery, Inc. (the appellant) from a decision of the Court of First Instance of Negros Occidental in Civil Case No. 7355.
- The court ordered the appellant to pay the City of Bacolod (the appellee) a sum of P36,519.10, representing surcharges on certain fees that the appellant should have paid quarterly from July 1959 to December 1962.
- The appellant paid these fees only on April 23, 1963.
Ordinance Background
- On February 17, 1949, the City Council of Bacolod enacted Ordinance No. 66, which imposed a fee on local manufacturers and bottlers of soft drinks.
- The original fee was fixed at ONE TWENTY-FOURTH (1/24) of a centavo per bottle, with a surcharge of 2% per month for delinquency, not exceeding 24% in one year.
- Ordinance No. 150, series of 1959, subsequently amended the fee to ONE-EIGHTH (1/8) of a centavo per bottle, increasing the tax from P0.01 to P0.03 per case of soft drinks.
Initial Legal Proceedings
- Following the enactment of the ordinances, the appellant only paid the original bottling tax of P0.01 per case and refused to pay the additional fees.
- In March 1960, the City filed Civil Case No. 5693 against the appellant to recover the underpaid taxes, amounting to P26,306.54.
- The case was resolved with a judgment on November 12, 1960, ordering the appellant to pay the correct tax of P0.03 per case from March 1960 onward.
Appeal and Subsequent Actions
- The appella