G.R. No. 72827 - Europa vs. Hunter Garments Manufacturing Incorporated

The court's jurisdiction over the private respondent was established when it filed a motion for reconsideration of the judgment by default and a motion to admit an answer based on excusable negligence.
Even if the court initially lacked jurisdiction, the private respondent's actions constituted a submission to the court's authority.
The denial of both motions by the lower court is binding on the private respondent, as established in the precedent case Soriano vs. Palacio.

In cases of quasi-delict, all damages that are the natural and probable consequences of the act or omission are recoverable, as per Article 2202 of the New Civil Code.
This principle underpins the legal framework for the damages sought by the petitioner in this case.

The petitioner, Lucia Europa, filed an action for damages against Hunter Garments Manufacturing (Philippines) Incorporated after her daughter, Lucrecia Europa, was electrocuted while operating a sewing machine on March 9, 1978.
The summons and complaint were served to the production manager, but no answer was filed, leading to a default judgment in favor of the petitioner.
The trial court awarded damages totaling P62,580.00, including amounts for death, actual expenses, loss of income, moral damages, and attorney's fees.

The private respondent filed a motion for reconsideration and a motion to admit an answer, citing excusable negligence due to the failure of a secretary to forward the summons.
The trial court denied these motions, prompting the private respondent to appeal to the Court of Appeals.
The Court of Appeals found that the trial court lacked jurisdiction due to improper service of summons and set aside the default judgment, ordering further proceedings.

The Supreme Court found merit in the petition for certiorari, asserting that the private respondent had submitted to the court's jurisdiction through its motions.
The evidence indicated that Lucrecia died from electrocution, confirmed by an autopsy report.
The lower court's findings highlighted gross negligenc...continue reading