Case Summary (G.R. No. 134888)
Summary of Events
RAM'S was contracted on November 8, 1994, for the wedding video. Unfortunately, the photographers arrived late at 7:00 PM, after the ceremony commenced. Furthermore, the captured videotape was found to be damaged, displaying only a brownish-black screen during the initial thirty minutes. RAM'S offered to retake the damaged sections at no additional cost, which the Rivieras declined. Consequently, the Rivieras filed a complaint for damages in the Regional Trial Court of Muntinlupa City on July 5, 1995.
Court Proceedings
The Rivieras amended their complaint on August 23, 1995, and RAM'S failed to respond within the required period, resulting in a default judgment on January 22, 1996. The court awarded the Rivieras actual damages of ₱5,950, moral damages of ₱500,000, exemplary damages of ₱500,000, and attorney's fees amounting to ₱100,000 and ₱2,000 per appearance. RAM'S attempted to file a motion for new trial after the reglementary period, which was received by their counsel on April 10, 1996, and denied execution was ordered on January 14, 1997.
Appellate Review
Upon RAM'S motion for reconsideration, the lower court had initially granted a trial for RAM'S before reversing course upon the Rivieras’ request, standing by previous timelines indicating that the motion for new trial was filed one day late, after the ruling had become final. RAM'S motion was referred to the Court of Appeals.
Legal Issue Consideration
The core legal issue centered on the timely filing of the motion for new trial. RAM'S contended that the motion was timely based on their receipt date of the judgment decision, arguing that the clock should begin upon the new counsel's receipt on April 11, 1996, instead of the previous counsel’s earlier communication. The Court of Appeals ruled against this, asserting valid notice to the original counsel sufficed for legal notice to RAM'S, making the appeal deadline final.
Court's Rationale
Citing established legal principles, the Court denoted the critical nature of rigorous adherence to procedural rules regarding the perfection of appeals as jurisdictional. It emphasized that any failure to observe these timeline
...continue readingCase Syllabus (G.R. No. 134888)
Case Overview
- The case involves a Petition for Review on Certiorari under Rule 45 by Ram's Studio and Photographic Equipment, Inc. (RAM'S) challenging the decisions and resolutions of the Court of Appeals.
- The petition seeks to overturn the Court of Appeals’ Decision dated 20 February 1998 and Resolution dated 27 July 1998, which set aside the orders of the lower court dated 6 March 1997 and 24 June 1997.
Factual Background
- RAM'S, managed by Daniel J. Daffon, was contracted by Gina Cynthia Hernal to provide video coverage for her wedding scheduled for 27 January 1995 at 6:00 PM.
- The photographers arrived late, causing the bride to commence her entrance at 7:00 PM.
- Upon claiming the videotape, the bride discovered it was damaged, showing only a brownish-black screen during the first thirty minutes.
- RAM'S offered to retake the damaged footage at no cost, but this offer was rejected by the respondents.
- On 5 July 1995, the respondents filed a complaint for damages against RAM'S in the Regional Trial Court of Muntinlupa City.
Legal Proceedings in the Lower Court
- The respondents amended their complaint on 23 August 1995, prior to any responsive pleading from RAM'S.
- RAM'S requested extensions to answer but ultimately failed to respond, leading to a declaration of default on 22 January 1996.
- Following an ex-parte presentation of evidence by the respondents, the lo