Case Summary (G.R. No. 97535)
Procedural Background
On August 21, 1990, La Campana filed a complaint against Meralco seeking to recover amounts owed due to differential billing for alleged meter tampering and underbilling due to meter malfunction. The initial assignment of the case was to Branch 78 of the Regional Trial Court of Quezon City but was subsequently re-raffled to Branch 80 due to the inhibition of Judge Percival M. Lopez. Meralco's filings and motions, including a motion for extension of time to answer and its eventual answer with counterclaim, followed a series of procedural missteps, including failing to comply with the notice of hearing requirements stipulated in the Rules of Court.
Judgment and Subsequent Filings
Despite filing a late answer, La Campana filed a motion to declare Meralco in default, which Judge Dayaw granted on October 8, 1990. This led to a judgment on November 20, 1990, ordering Meralco to reconnect the electricity service, return amounts paid with interest, and pay attorney's fees. Meralco subsequently filed a “Motion to Set Aside Judgment by Default and/or for New Trial” on December 3, 1990, which was denied by Judge Dayaw for lack of adequate grounds.
Appeal Issues
Meralco's notice of appeal filed on January 28, 1991, was challenged by La Campana as tardy, arguing that the expiration for filing an appeal had passed on December 14, 1990. The trial court concurred and denied the notice of appeal on February 22, 1991, allowing La Campana’s motion for execution to proceed, appointing Deputy Sheriff Martinez as special sheriff to enforce the writ of execution.
Petition for Certiorari
On March 15, 1991, Meralco filed a petition for certiorari and prohibition, claiming that Judge Dayaw exhibited grave abuse of discretion. However, the Supreme Court found that Meralco's procedural errors—including filing its motion for extension without a proper notice of hearing—rendered its motions ineffective. The Court reaffirmed that such a motion is deemed a worthless filing under the Rules of Court, leading to its failure to timely respond to the original complaint.
Court's Findings
The Supreme Court thoroughly examined the case and identified that no grave abuse of discretion occurred. Meralco's failure to comply with procedural requirements led to its default status, wherein it forfeited its rights to participate in the trial process. Furthermore, the Court clarif
...continue readingCase Syllabus (G.R. No. 97535)
Case Background
- On August 21, 1990, La Campana Food Products, Inc. filed a complaint against Manila Electric Company (Meralco) for recovery of a sum of money and sought a preliminary injunction.
- The complaint arose following a notice of disconnection issued by Meralco for alleged non-payment of bills, which included:
- A differential billing of P65,619.26 for unregistered electric energy due to alleged tampering on September 22, 1986.
- An underbilling amounting to P169,941.29 (with a remaining balance of P28,323.55) for the period from January 16, 1987, to December 16, 1987, resulting from meter multiplier failure.
- Summons and a copy of the complaint were served to Meralco on August 23, 1990.
- The case was initially assigned to Branch 78 of the Regional Trial Court of Quezon City, presided over by Judge Percival M. Lopez, but was re-raffled to Branch 80 under Judge Benigno T. Dayaw on September 25, 1990.
Procedural History
- Meralco filed a motion on September 7, 1990, requesting a fifteen-day extension to answer the complaint, which was not acted upon due to lack of a notice of hearing.
- Meralco's answer was received on September 21, 1990, past the reglementary period but within the requested extension.
- On September 28, 1990, La Campana moved for an ex parte declaration of default against Meralco, which was granted by Judge Dayaw on October 8, 1990.
- Following a hearing where only La Campana's evidence was