Case Summary (G.R. No. L-31690)
Procedural History
Hartford Fire Insurance Co. filed Civil Case No. 75781 against E. Razon, Inc. on February 20, 1969. A pre-trial conference was held on May 19, 1969, resulting in stipulations between the parties. Following these stipulations, the trial court rendered a decision on July 11, 1969, ruling against E. Razon, Inc., and ordering it to pay approximately P8,000 to Hartford. E. Razon, Inc. appealed this decision on August 7, 1969, but the appeal was dismissed by the trial court on August 30, 1969, on the grounds that it involved only questions of law.
Reason for Dismissal of the Appeal
The trial court dismissed the appeal by asserting that due to the stipulation of facts agreed upon by both parties, no factual questions were at issue, thus requiring that any appeal should directly go to the Supreme Court via Certiorari as mandated by Republic Act No. 5440. This ruling, however, was subsequently set aside by the trial court as it acknowledged the premature issuance of the dismissal order but reaffirmed the dismissal based on the nature of the questions involved.
Motion for Mandamus
In response to the dismissal, E. Razon, Inc. sought a Writ of Mandamus from the Court of Appeals requesting approval of its Record on Appeal. However, on November 24, 1969, the Court of Appeals denied the petition for Mandamus, agreeing with the trial court's assessment that the matter only involved questions of law which should be elevated to the Supreme Court.
Court of Appeals Decision
The Court of Appeals' decision was fundamentally wrong in upholding the disallowance of E. Razon's appeal. While purely legal matters fall under the Supreme Court's jurisdiction, the Rules of Court do not authorize a trial court to dismiss an appeal solely on the basis of the absence of factual questions. The pertinent rule stipulates that an appeal, if timely presented and in compliance with legal requirements, should be allowed.
Implications of the Decision
The Supreme Court acknowledged procedural errors in the trial court’s dismissal of the appeal. However, it concluded that issuing a Writ of Mandamus would not serve a practical purpose. The core issue—the applicability of the Revised Management Contract—wa
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Case Overview
- This case revolves around an appeal by Certiorari from the Decision of the Court of Appeals, issued on November 24, 1969, which denied a Petition for Mandamus filed by petitioner E. Razon, Inc.
- The appeal also contests a subsequent Resolution dated February 5, 1970, which denied the petitioner’s Motion for Reconsideration.
- The underlying matter involves Civil Case No. 75781 initiated by Hartford Fire Insurance Company against E. Razon, Inc. for a sum of money, with the case assigned to respondent Judge Jose L. Moya.
Procedural History
- On February 20, 1969, Hartford Fire Insurance Co. filed a complaint against E. Razon, Inc.
- A pre-trial conference on May 19, 1969, led to several stipulations regarding the handling of cargo and the applicability of the Revised Management Contract.
- The trial court rendered a Decision on July 11, 1969, ruling that the Revised Management Contract did not apply due to total non-delivery of the shipment, condemning E. Razon, Inc. to pay over P8,000.00 to Hartford.
- E. Razon filed a Notice of Appeal on August 7, 1969, and subsequently submitted a Record on Appeal on August 15, 1969.
- Hartford filed a Motion to Dismiss the Appeal on August 27, 1969, arguing that the appeal should have been filed by Certiorari to the Supreme Court due to the nature of the questions involved.
Dismissal of the Appeal
- On August 30, 1969, respondent Judge dismissed the appeal, citing that only ques