Case Summary (G.R. No. 57079)
Factual Background
Private respondents alleged that on the evening of July 30, 1968 their jeep struck a mound of earth and fell into an open trench excavated by PLDT for an underground conduit system, causing injuries to Gloria Esteban and minor injuries to Antonio Esteban and damage to their vehicle. The complaint attributed the occurrence to the absence of warning lights or signs and to the trench being left uncovered as darkness fell. PLDT answered denying liability, contending contributory negligence by Antonio Esteban and fault, if any, of its contractor, L.R. Barte and Company.
Third-Party Plea and Contractor's Response
PLDT filed a third-party complaint against L.R. Barte and Company asserting contractual terms relieving PLDT from liability for accidents arising from Barte’s negligence. Barte replied that it had not been notified of the accident, that it had installed barricades, standard signs and red lights at night as required under the contract, and that it had complied with safety measures at the work site.
Trial Court Proceedings and Decree
On October 1, 1974 the Court of First Instance rendered judgment for private respondents, awarding moral and exemplary damages to both spouses, attorney’s fees, and ordering Barte to reimburse PLDT for whatever amount PLDT paid to plaintiffs. The trial court thus imposed liability upon PLDT and cast costs against it.
Court of Appeals' Original Ruling
On September 25, 1979 the Special Second Division of the Court of Appeals reversed the trial court, found respondent spouses negligent, and dismissed their complaint, thereby absolving PLDT from liability. That decision was received by private respondents on October 10, 1979 and prompted their timely first motion for reconsideration filed October 25, 1979.
Motions for Reconsideration and Subsequent Proceedings
The Court of Appeals denied the first motion on January 24, 1980, a resolution received by private respondents on February 22, 1980. Private respondents then filed, on February 29, 1980, a motion for leave to file a second motion for reconsideration and filed the second motion on March 7, 1980. On March 11, 1980 the Court of Appeals issued a resolution allowing the filing and giving ten days to file the second motion; later, the court convened a five-justice division and, on September 3, 1980, set aside the original September 25, 1979 decision and affirmed the trial court. PLDT moved to set aside that September 3, 1980 resolution, and the Court of Appeals denied the motion on May 11, 1981.
Issues Presented to the Supreme Court
PLDT assailed the Court of Appeals’ allowance of the second motion for reconsideration and the subsequent reversal of its own original decision, arguing that the second motion and the leave to file it were filed out of time and pro forma, that the September 25, 1979 decision had become final and executory, and that the Court of Appeals thereby lacked jurisdiction to entertain further reconsideration; PLDT additionally contended that the independent contractor doctrine absolved it of liability for acts of Barte.
Supreme Court's Analysis on Procedural Finality
The Supreme Court reviewed the chronological record and concluded that private respondents filed their first motion for reconsideration on the last day of the fifteen-day reglementary period, leaving only one day to file, with leave, a second motion under Section 1, Rule 52, Rules of Court. The Court found that private respondents failed to act within that remaining time and that both their motion for leave filed on February 29, 1980 and the second motion filed on March 7, 1980 were therefore time-barred. The Court held that the Court of Appeals lost power to take further proceedings on the merits after the expiration of the reglementary period and that the March 11, 1980 resolution granting leave and extending ten days was null and void because an extension cannot be granted after the period sought to be extended has expired.
Supreme Court's Conclusion on Jurisdiction and Finality
The Court reaffirmed the elementary rule that once a judgment becomes final and executory it is removed from the power and jurisdiction of the court which rendered it and that a court’s inherent power to correct its own errors must be exercised before finality. Relying on applicable authorities and Section 3, Rule 52, Rules of Court, the Court held that the subsequent resolutions of March 11, 1980 and September 3, 1980 were null and void and could not disturb the finality of the September 25, 1979 decision. The Supreme Court therefore set aside the Court of Appeals’ later resolutions and reinstated the original September 25, 1979 decision.
Supreme Court's Review of the Merits
Prescinding from the procedural infirmities, the Supreme Court examined the merits and found no error in the Court of Appeals’ original factual findings that the accident resulted from the lack of diligence of respondent Antonio Esteban and not from any proven negligent omission by PLDT. The
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Case Syllabus (G.R. No. 57079)
Parties and Procedural Posture
- PHILIPPINE LONG DISTANCE TELEPHONE CO., INC. (PLDT) filed a petition for review on certiorari assailing resolutions and decisions of the Court of Appeals in an action for damages originally instituted in the Court of First Instance of Negros Occidental.
- Spouses Antonio Esteban and Gloria Esteban were the private respondents who sued PLDT for injuries sustained when their jeep ran over an excavation mound and fell into an open trench.
- L.R. Barte and Company (Barte) was impleaded by PLDT as third-party defendant and was ordered by the trial court to reimburse any amount PLDT paid to plaintiffs, but Barte did not appeal.
- The Court of Appeals initially rendered a decision dated September 25, 1979 dismissing the complaint and absolving PLDT, later issued a denial of the first motion for reconsideration on January 24, 1980, then allowed a second motion for reconsideration and, in a subsequent division of five, promulgated a resolution on September 3, 1980 setting aside its original decision and affirming the trial court.
- The Supreme Court entertained PLDT’s petition and addressed both the procedural propriety of the second motion for reconsideration and the substantive allocation of negligence.
Key Factual Allegations
- The accident occurred on the evening of July 30, 1968 when the respondents' jeep hit an earth mound and fell into an open trench allegedly excavated for installation of PLDT’s underground conduit system.
- Gloria Esteban allegedly suffered injuries to her arms, legs and face with a permanent cheek scar, while Antonio Esteban allegedly suffered cut lips and the jeep’s windshield was shattered.
- Plaintiffs alleged the trench was left uncovered and unlighted with no warning signs or lights, and that creeping darkness prevented notice of the excavation.
- Barte averred in the third-party answer that it had installed standard warning signs, barricades and red lights at night in accordance with its contract with PLDT.
Trial Court Decision
- The Court of First Instance rendered judgment in favor of private respondents and ordered PLDT to pay moral and exemplary damages to both spouses, interest from filing, and attorney’s fees, and ordered third-party defendant Barte to reimburse whatever amount PLDT paid.
- The decretal awards included PHP 20,000 and PHP 5,000 for moral and exemplary damages to the wife and smaller amounts to the husband, together with attorney’s fees and costs.
Court of Appeals Proceedings
- The Special Second Division of the Court of Appeals dated September 25, 1979 reversed the trial court and dismissed the complaint upon finding plaintiffs negligent.
- Private respondents filed a first motion for reconsideration on October 25, 1979 which the Court of Appeals denied by resolution dated January 24, 1980, receipt of which occurred February 22, 1980.
- Private respondents filed a motion for leave to file a second motion for reconsideration on February 29, 1980 and filed the second motion on March 7, 1980, after which the Court of Appeals on March 11, 1980 allowed leave and gave ten days to file the second motion.
- Because of divergent opinions, the Court of Appeals later designated a division of five which on Sept