Case Summary (G.R. No. 146224)
Procedural Posture
Respondent sued petitioner for damages in the Metropolitan Trial Court (MeTC), alleging negligence in equipment upkeep and employee supervision. The MeTC rendered judgment on April 5, 1999 in favor of respondent, awarding ₱50,000 temperate damages and ₱25,000 attorney’s fees. Petitioner appealed to the Regional Trial Court (RTC), which on November 26, 1999 affirmed liability but increased temperate damages to ₱80,000. Petitioner’s motion for reconsideration was denied on April 12, 2000. A petition for review before the Court of Appeals (CA) was dismissed outright on June 16, 2000 for procedural deficiencies; reconsideration was denied on November 27, 2000. Petitioner then filed a Rule 45 petition with the Supreme Court.
Applicable Law
– 1987 Constitution (decision after 1990)
– Rule 42, Section 2 and Rule 45, Revised Rules of Court (form and content of CA petitions)
– Article 2176 and Article 2180, Civil Code (quasi-delict and employer liability)
Compliance with Procedural Requirements
Rule 42, Section 2 mandates that petitions for review to the CA include certified true copies of lower-court decisions signed by the Clerk of Court, plus pleadings or record portions supporting allegations. Petitioner initially submitted uncertified copies and omitted certain pleadings, prompting CA dismissal. The Supreme Court recognized that clerk certification is mandatory but applied the doctrine of substantial compliance. Upon petitioner’s timely submission of true copies certified by the Clerk in her motion for reconsideration, the Court found procedural deficiencies cured and CA’s outright dismissal a grave abuse of discretion.
Liability and Fortuitous Event
Under Article 1174, Civil Code, a fortuitous event must be independent of human agency, unforeseeable or unavoidable, and free from obligor participation. Evidence established:
- Fire originated from leaking LPG equipment under petitioner’s control.
- Petitioner’s employees failed to detect or control the leak.
- No proof of natural forces or unforeseeable causes.
Petitioner’s claim of fortuity failed. Pursuant to Articles 2176 and 2180, negligence by petitioner or her employees imposes liability for resulting damages. A presumption of employer negligence arises from employee fault; petitioner did not rebut it by demonstrating diligence in equipment maintenance or employee supervision.
Award of Damages
The MeTC awarded ₱50,000 temperate damages and ₱25,000 attorney’s fees. The RTC, on appeal by petitioner alone, lacked authority to increase tem
Case Syllabus (G.R. No. 146224)
Facts of the Case
- Petitioner Virginia Real owned and operated the Wasabe Fastfood stall at the Philippine Women’s University Food Center in Manila.
- Respondent Sisenando H. Belo owned and operated the adjacent BS Masters fastfood stall in the same Food Center.
- On January 25, 1996, at around 7:00 a.m., a fire originated at the Wasabe Fastfood stall.
- Fire Investigator SFO1 Arnel C. Pinca determined that the blaze was caused by leaking fumes from the liquefied petroleum gas (LPG) stove and tank at petitioner’s stall.
- The fire spread rapidly, destroying petitioner’s stall and respondent’s stall, among others.
Procedural History
- Respondent filed a complaint for damages in the Metropolitan Trial Court (MeTC), alleging petitioner’s negligence in equipment maintenance and employee supervision.
- In her Answer, petitioner denied liability, characterizing the fire as a fortuitous event and claiming she had exercised due diligence.
- The MeTC rendered judgment on April 5, 1999, in favor of respondent, awarding PHP 50,000 temperate damages and PHP 25,000 attorney’s fees.
- Petitioner appealed to the Regional Trial Court (RTC), which on November 26, 1999 affirmed the MeTC decision but increased temperate damages to PHP 80,000.
- Petitioner’s Motion for Reconsideration in the RTC was denied on April 12, 2000.
- Petitioner then filed a petition for review with the Court of Appeals (CA), which on June 16, 2000 dismissed it for procedural defects and on November 27, 2000 denied reconsideration.
- Petitioner elevated the case to the Supreme Court via Rule 45 certiorari.
Issues Presented
- Whether certified copies of lower‐court decisions authenticated by a court employee other than the Clerk of Court satisfy Rule 42, Section 2 requirements.
- Whether a certified copy of the MeTC decision is indispensable when the RTC decision is the proper subject of petition for review.
- Whether submission of parties’ position papers and witness affidavits is indispensable when their contents are quoted in the petition and MeTC decision.
- Whether petitioner can be held liable for damages resulting from the fire that