Case Summary (G.R. No. 252790)
Facts of the Case
Holcim initiated proceedings against Malayan on May 16, 2011, filing a complaint for sum of money that included claims for actual and exemplary damages, as well as attorney's fees. Initially, Judge J. Cedrick O. Ruiz presided over the case at the RTC of Makati City. As the case progressed, Malayan attempted to file a Motion to Dismiss the complaint, but this was denied. Following this, Malayan failed to file a responsive pleading, leading Holcim to move for a declaration of default against Malayan, which was granted by the RTC on February 17, 2012.
RTC Proceedings and Orders
In response to the order of default, Malayan sought to admit its answer to the complaint, claiming that its counsel's oversight was due to personal issues. The RTC denied this motion, asserting that Malayan's counsel had not followed proper procedures under the Rules of Court, specifically citing the failure to provide a sworn motion to set aside the default order. Malayan appealed this decision to the Court of Appeals (CA), which upheld the RTC’s ruling in subsequent petitions.
CA Ruling
After the RTC issued a decision in favor of Holcim on May 2, 2013, Malayan's attempts to challenge the default order continued. The CA later nullified the RTC's resolutions that had lifted Malayan's default status, indicating that the default order had become final and immutable. The CA determined that the RTC had gravely abused its discretion in overturning the default, given that an earlier final resolution had already been established regarding Malayan's default.
Issue Presented
The central issue was whether the CA erred in ruling that the RTC had committed grave abuse of discretion in its issuance of resolutions that attempted to lift the order of default against Malayan. Malayan contended that, in light of the unique circumstances surrounding the case, it had appropriately sought to lift the order of default.
Court's Ruling
The Supreme Court concurred with the CA's assessment, reiterating fundamental procedural rules regarding default and the immutability of judgments. The Court emphasized that the doct
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Case Overview
- The case involves a Petition for Review on Certiorari filed by Malayan Bank Savings and Mortgage Bank (Malayan) against Holcim Philippines, Inc. (Holcim) concerning the annulment of certain Resolutions issued by the Regional Trial Court (RTC) of Makati City.
- The Court of Appeals (CA) annulled the Resolutions dated June 3, 2016, and June 9, 2017, asserting that the RTC had gravely abused its discretion in lifting an order of default against Malayan.
Procedural History
- Holcim filed a Complaint against Malayan on May 16, 2011, for failing to honor an irrevocable letter of credit, seeking damages.
- Malayan initially filed a Motion to Dismiss, which was denied by Judge J. Cedrick O. Ruiz of the RTC.
- Holcim subsequently moved to declare Malayan in default due to its failure to answer, leading to the RTC's Order of Default on February 17, 2012.
- Malayan’s Motion to admit its answer was denied, prompting a series of appeals and petitions, including a Petition for Certiorari which was dismissed by the CA and later by the Supreme Court due to various procedural failures.
Key Facts
- The RTC ruled in favor of Holcim on May 2, 2013, ordering Malayan to pay substantial damages and attorney's fees.
- Following the conviction of Judge Ruiz, the Court directed a review of his decisions, leading to the RTC recalling its prior ruling on the case.
- Malayan filed a Comment with Omnibus Motion, requesting to lift the default order, which was granted by the RTC in its June 3, 2016 Resolution.