Case Summary (G.R. No. 159813)
Facts and Procedural History
The case arose from an accident on July 30, 1968, where the jeep driven by Antonio Esteban struck a mound of earth and fell into an open trench excavated allegedly by PLDT for underground conduit installation. The trench was reportedly left uncovered without warning signs or lights, resulting in injuries to Gloria Esteban and minor injuries to Antonio Esteban alongside damage to their jeep. The respondents sued PLDT for damages, while PLDT countered by attributing liability to the independent contractor, Barte, who conducted the excavation work.
At trial, the Court of First Instance ruled in favor of the Estebans, awarding moral and exemplary damages as well as attorney’s fees against PLDT and ordering Barte to reimburse PLDT. Both PLDT and the Estebans appealed, with the latter contesting only the damages amount.
Court of Appeals Proceedings
The Court of Appeals Special Second Division reversed the trial court decision, dismissing the Estebans' complaint and exonerating PLDT on grounds of negligence by the Estebans. The respondents filed a first motion for reconsideration, which was denied. Subsequently, they filed a motion for leave to file a second motion for reconsideration after the reglementary period expired, which the Court of Appeals initially granted, allowing a second motion to be filed. The five-member panel later reversed the original decision anew in favor of the Estebans.
PLDT moved to reconsider this second reversal, contending that the second motion for reconsideration was untimely and that the Court of Appeals' original decision had become final and executory, invoking the independent contractor doctrine to deny liability.
Issues Presented
- Whether the second motion for reconsideration filed by respondents was timely and properly entertained by the Court of Appeals.
- Whether PLDT can be held liable under the independent contractor rule for the accident involving the trench excavation conducted by Barte.
Timeliness and Jurisdiction Analysis
Applying the procedural rules governing motions for reconsideration prior to the 1987 Constitution, particularly Section 1, Rule 52 of the Rules of Court, the Supreme Court found that respondents’ second motion for reconsideration was filed beyond the prescribed period. The first motion for reconsideration consumed nearly the entire reglementary 15-day period, leaving respondents only one day to file a second motion following receipt of the denial resolution. Instead, respondents filed the motion for leave six days after this period elapsed. Consequently, the Court of Appeals lost jurisdiction to entertain the subsequent motions, rendering the resolutions allowing the second motion void and without legal effect.
The Supreme Court underscored the principle that once a decision becomes final and executory after the lapse of the proper period to appeal or move for reconsideration, the court that rendered the decision can no longer amend, alter, or modify it. This prevents endless litigation and promotes finality.
Substantive Merits: Liability for Negligence
Evaluating the evidence, the Court held that the accident was primarily due to the negligence of Antonio Esteban as the driver. Findings showed his jeep was running faster than claimed and swerved from the proper lane, striking the accident mound. Despite knowledge of the excavation area, Esteban failed to exercise proper care, such as using regular headlights on a dimly lit and drizzling night, which could have prevented the accident. The alleged absence of warning signs or lights was not the proximate cause since the accident was caused by Esteban’s sudden swerve and lack of due diligence.
The Court further noted the lack of credible evidence supporting respondents’ claims—no police report, absent medical records, and reliance on self-serving testimony without corroboration. The contractor Barte complied with safety standards by placing standard signs and barricades.
Application of the Independent Contractor Rule
PLDT argued it could not be held liable for the negligence of Barte, an independent contractor. The Court did not find error in the trial court’s application of this doctrine, as there was insufficient proof of PLDT’s negligence or control over Barte’s work. Liability did not attach to PLDT as the principal for acts or omissions of the indepe
Case Syllabus (G.R. No. 159813)
Case Background and Origin
- The case arose from an action for damages filed by Spouses Antonio and Gloria Esteban against Philippine Long Distance Telephone Company (PLDT) in the former Court of First Instance of Negros Occidental.
- The accident occurred on the evening of July 30, 1968, when the Estebans' jeep ran over a mound of earth and fell into an open trench, allegedly excavated by PLDT for installation of an underground conduit system.
- The complaint alleged that the open trench was left uncovered and unmarked by warning signs or lights, and that Antonio Esteban failed to notice the trench in the creeping darkness.
- Gloria Esteban sustained injuries on her arms, legs, and face, with an alleged permanent scar on her cheek; Antonio Esteban suffered cut lips; the jeep’s windshield was shattered.
- PLDT denied liability, asserting respondent spouses were negligent and that the actual responsible party, if any, was independent contractor L.R. Barte and Company (Barte), which undertook the construction of the conduit system and manhole.
Third-Party Complaint and Defense
- PLDT filed a third-party complaint against Barte, citing a contractual clause exempting PLDT from liability arising from Barte’s negligence or that of its employees.
- Barte responded that it had no knowledge nor was it notified of the accident and had complied with the contract’s requirements: appropriate standard warning signs, barricades at excavation ends, and red lights at night to warn the public.
Trial Court Decision
- On October 1, 1974, the trial court rendered judgment in favor of the Estebans, ordering PLDT to pay Gloria Esteban damages for moral (₱20,000) and exemplary (₱5,000) damages, and Antonio Esteban moral (₱2,000) and exemplary (₱500) damages plus attorney’s fees (₱3,000), with legal interest.
- The court also ordered Barte to reimburse PLDT any amounts paid to the Estebans.
- Both PLDT and Estebans appealed; Barte did not.
Court of Appeals’ First Decision and Subsequent Motions
- On September 25, 1979, the Court of Appeals Special Second Division reversed the trial court decision, dismissing the Estebans’ complaint on grounds of respondent spouses’ negligence and absolving PLDT of liability.
- Private respondents received a copy of this decision on October 10, 1979, and timely filed a motion for reconsideration on October 24, 1979.
- On January 24, 1980, their motion was denied; the resolution was received by the Estebans on February 22, 1980.
- On February 29, 1980, the Estebans filed a motion for leave to file a second motion for reconsideration and subsequently filed the second motion on March 7, 1980, both beyond the reglementary period.
- Despite the late filing, on March 11, 1980, the Court of Appeals Special Ninth Division allowed the filing of the second motion for reconsideration, granting a 10-day extension.
- The extension was received April 1, 1980, but the second reconsideration motion had already been filed.
Court of Appeals’ Reconsideration and PLDT’s Motion to Set Aside
- Due to diverging opinions, the Court of Appeals formed a five-member division on the case.
- The five-person division on September 3, 1980, set aside the earlier CA decision and resolution and affirmed the trial court’s original decision awarding damages in favor of the Estebans.
- PLDT moved to set aside this resolution on September 19, 1980, arguing the second mo