G.R. No. 103287-88 - People vs. Machete

Case Summary (G.R. No. 103287-88)

Procedural History and Applicable Law

The complaint for damages was filed on November 7, 1979, by the heirs of Reinoso against Tapales and Guballa. Guballa filed a third-party complaint against Filwriters Guaranty Assurance Corporation under Policy No. OV-09527. The Regional Trial Court (RTC), Branch 8, Manila, rendered a decision on March 22, 1988, awarding damages to the petitioners against Guballa and to Tapales against Guballa, and holding the insurer liable under the policy.

On appeal, the Court of Appeals (CA) set aside and reversed the RTC decision on May 20, 1994, dismissing the complaint on the ground of non-payment of docket fees in accordance with the doctrine in Manchester Corporation v. Court of Appeals, 233 Phil. 579 (1987). The CA reasoned that prescription barred the payment of correct docket fees at that stage. A motion for reconsideration was denied on June 30, 1994. The petitioners filed the present petition for review.

The case decision was rendered in 2011, thus applying the 1987 Philippine Constitution and procedural rules under the Rules of Court.

Issue on Non-Payment of Docket Fees and Jurisdiction

The petitioners argued that the CA misapplied the Manila Corporation ruling, applying the doctrine retroactively, which should not apply to cases filed before 1987. They contended that the specification of damages was not an issue, that payment of docket fees should not deprive the trial court of jurisdiction if corrected promptly, and that the issue of docket fee payment was not raised by the RTC or CA prior to the dismissal.

The Supreme Court acknowledged that while payment of docket fees is mandatory to confer jurisdiction, the strict rule in Manchester was subsequently relaxed in Sun Insurance Office, Ltd. v. Asuncion, 252 Phil. 280 (1989), to allow payment within a reasonable time but not beyond the prescriptive period. The Court adopted a liberal approach where there is no bad faith or intent to defraud, allowing payment of additional fees, as reaffirmed in United Overseas Bank v. Ros, G.R. No. 171532 (2007).

The Court noted that procedural rules are tools to facilitate justice and must not obstruct substantive rights. Given the petitioners filed the complaint before Manchester and the CA dismissed the case motu proprio without raising the issue earlier, strict application would lead to injustice. Therefore, the Court exercised judicial discretion to suspend the strict application of the rule to allow resolution on the merits.

Liability for the Collision and Negligence

The factual circumstances were undisputed: Ruben Reinoso, Sr. was killed after a collision involving the jeepney owned by Tapales and driven by Alejandro Santos, and a sand and gravel truck owned by Guballa and driven by Mariano Geronimo. The collision happened near E. Rodriguez Avenue, where road repairs and a wooden barricade were present.

The evidence, including testimony from the jeepney driver and passengers and an official police sketch prepared immediately after the accident, established that the truck driver suddenly swerved left at high speed to avoid the barricade, encroaching on the jeepney's lane and causing the collision. The jeepney was traveling on its proper side at moderate speed.

The Court found that the primary cause was the truck driver's negligence in speed and lane control, violating Section 37 of Republic Act No. 4136 (Land Transportation and Traffic Rules) which mandates driving on the right side except for safety reasons.

Employer Liability and Presumption of Negligence

Under Articles 2176 and 2180 of the Civil Code, an employer is liable for damages caused by employees acting within the scope of their employment unless the employer proves exercise of due diligence akin to that of a "good father of a family."

The Court affirmed the RTC's finding that Guballa failed to rebut the presumption of negligence with regard to the selection and supervision of the truck driver. The measures claimed by Guballa—periodic checks of the vehicle and accompanying helpers—were deemed insufficient to discharge this burden.

Damages Awarded

The RTC a

Case Syllabus (G.R. No. 103287-88)

Case Background and Procedural History

The case arises from a vehicular accident on June 14, 1979, involving a passenger jeepney and a truck on E. Rodriguez Avenue, Quezon City.
Ruben Reinoso, Sr., a passenger in the jeepney, died due to the collision.
The jeepney was owned by Ponciano Tapales and driven by Alejandro Santos; the truck was owned by Jose Guballa and driven by Mariano Geronimo.
On November 7, 1979, the heirs of the deceased filed a complaint for damages against Tapales and Guballa.
Guballa subsequently filed a third-party complaint against Filwriters Guaranty Assurance Corporation (FGAC) under an insurance policy.
On March 22, 1988, the Regional Trial Court (RTC), Branch 8, Manila rendered judgment in favor of the petitioners and against Guballa, awarding various damages totaling ₱250,000 to the heirs and other sums for property damages and insurance liabilities.
The Court of Appeals (CA), on May 20, 1994, reversed and set aside the RTC decision, dismissing the complaint due to non-payment of docket fees per the ruling in Manchester v. Court of Appeals.
The CA also ruled that prescription barred the petitioners from subsequently paying the docket fees.
A motion for reconsideration by petitioners was denied by the CA on June 30, 1994.
The petitioners thereafter filed the instant appeal to the Supreme Court.

Issues Presented for Resolution

Whether the CA correctly applied the ruling in Manchester v. Court of Appeals to dismiss the case for non-payment of correct docket fees.
Whether the specification of damages in the complaint, which was never contested at trial or appealed, could affect the case's merits.
Whether the primary issue revolves around the negligence and liability of the respondents for the death of Ruben Reinoso, Sr.
Whether the rulings on procedural dismissals should be applied retroactively to a complaint filed prior to such rulings.
Whether the petitioners should be allowed to prosecute their claims on the merits despite the alleged procedural defects.

Supreme Court’s Findings on Payment of Docket Fees and Jurisdiction

The Court acknowledged the general rule that payment of docket fees within the prescribed time is mandatory.
The Manchester ruling holds that jurisdiction is acquired only upon payment of the correct docket fee.
However, this strict rule was relaxed later in Sun Insurance Office, Ltd. v. Asuncion, allowing payment within a reasonable time before prescription or reglementary periods lapse.
United Overseas Bank v. Ros reaffirmed that if a party shows no intent to defraud and willingness to pay fees, the relaxed doctrine applies.
The Court has historically leaned towards liberal application to allow parties to fully ventilate their cases on merits rather than be dismissed on technical grounds.
In La Salette College v. Pilotin, the Court declared that failure to pay docket fees permits discretionary—not automatic—dismissal.
Recognizing competing interests betwee