Case Summary (G.R. No. 106483)
Applicable Law
The legal framework governing the case includes the provisions of the 1987 Philippine Constitution and the Revised Rules of Court regarding breach of contract, negligence, and damages.
Facts of the Case
Private respondents, Pedro and Lydia Santos, filed a complaint against petitioners on July 15, 1992, for breach of contract of carriage and damages. They claimed compensation for the death of their son, Joey Santos, who died in a bus accident allegedly caused by the gross negligence of the bus driver, Carlos Salonga. The Santos’ sought a total of P122,000.00 in damages, comprising P50,000.00 for wrongful death, P50,000.00 for moral damages, P20,000.00 for funeral expenses, and P20,000.00 for attorney's fees.
Proceedings in the Regional Trial Court
During pre-trial proceedings, petitioners failed to appear or file a pre-trial brief, leading the trial court to declare them in default and allow the respondents to present evidence ex parte. On November 4, 1992, the trial court ruled in favor of the Santos, awarding them P50,000.00 in compensatory damages, P12,000.00 for funeral expenses, and P10,000.00 for attorney's fees.
Petitioners' Motion to Set Aside Default
On November 10, 1992, petitioners, now represented by a new law firm, filed a motion to set aside the default order, claiming they were not notified of the pre-trial due to the resignation of their previous counsel. The trial court denied this motion on December 10, 1992.
Court of Appeals Ruling
Upon appeal, the Court of Appeals affirmed the trial court's decision but added P50,000.00 as moral damages, prompting petitioners to seek a review from the Supreme Court. They asserted that they were improperly declared in default and that the additional award of moral damages was erroneous as the respondents did not appeal the trial court's decision.
Supreme Court Decision
The Supreme Court determined that the trial court did not err in declaring the petitioners in default as they were duly notified through their counsel. The obligation to inform the client of pre-trial proceedings falls on the attorney, who must ensure that their clients are aware and present. The Court emphasized the importance of compliance with procedural rules and stated that the trial court had acted within its
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Case Background
- The petition for review on certiorari seeks to overturn the Court of Appeals' decision awarding damages to private respondents Pedro and Lydia Santos for the death of their son, Joey Santos, in a vehicular accident.
- The accident occurred on April 27, 1992, involving a passenger bus operated by Five Star Bus Co., Inc. and driven by Carlos Salonga, which allegedly collided with an oncoming trailer truck due to the driver's negligence.
- The Santos couple filed a complaint for breach of contract of carriage and damages before the Regional Trial Court (RTC) of Kalookan City on July 15, 1992, seeking a total of P122,000.00 in damages.
Nature of the Case
- The complaint was centered on the alleged gross negligence of the bus driver, leading to the fatal accident.
- The respondents sought P50,000.00 for the death of their son, P50,000.00 for moral damages, P20,000.00 for funeral expenses, and P20,000.00 for attorney's fees.
- In response, petitioners claimed that the negligence of the trailer truck driver was the actual cause of the accident.
Pre-Trial Proceedings
- A pre-trial conference was scheduled for October 15, 1992, with instructions for both parties to file pre-trial briefs.
- On the scheduled date, petitioners and their counsel failed to appear, resulting in the trial court declaring them in default and allowing the respondents to present their evidence e