Title
Saint Louis University vs. Cordero
Case
G.R. No. 144118
Decision Date
Jul 21, 2004
A student suffered permanent eye damage during a chemistry experiment due to lack of safety equipment. SLU and the instructor were found grossly negligent, but their appeal was dismissed for late payment of docket fees, binding them to the trial court’s ruling.

Case Summary (G.R. No. 144118)

Accident and Initial Medical Treatment

During a laboratory experiment involving anhydrous sodium acetate and barium hydroxide, a test tube burst, resulting in the chemicals striking Winston's face and eyes, leading to the total loss of sight in his right eye. Initially treated at the SLU hospital, Winston's injuries necessitated evacuation to St. Luke’s Medical Center in Manila for further medical attention, where he was hospitalized for five days before undergoing surgery to implant an artificial right eye.

Complaint for Damages

On January 24, 1996, the Corderos filed a complaint against SLU, its President Fr. Joseph Van Den Dailen, department chair Engr. Josephine Aries Dulay, Dean Eufracio de los Reyes, and Engr. Bautista, alleging gross negligence that resulted in Winston's injuries. After a trial, the Regional Trial Court rendered a decision on May 30, 1998, finding SLU and Bautista guilty of gross negligence.

Judgment and Subsequent Motions

The trial court ordered SLU and Bautista to pay various damages totaling over P1.6 million, including medical expenses, moral, and exemplary damages. The Corderos later filed a motion for reconsideration to increase damages, which led to an increase in the exemplary damages awarded. In total, the trial court's order raised the award significantly and mandated SLU and Bautista to compensate the Cordero spouses with moral damages.

Appeal Process

Following the trial court's decisions, SLU and Bautista filed their notices of appeal, although they did not initially pay the requisite docket and filing fees within the time limits prescribed by the 1997 Rules of Civil Procedure. The trial court accepted the notice of appeal despite the lack of fee payment. However, the Court of Appeals later denied their motion to admit the payment of these fees after the appeal period had elapsed.

Legal Arguments and Court of Appeals' Ruling

The petitioners argued that the gross negligence of their counsel, resulting in delays and procedural mishaps regarding docket fees, should not bind them, thus asserting their right to appeal. They invoked the principle that counsel's negligence should not deprive a client of due process. However, the respondents maintained that the actions taken by petitioners’ counsel constituted binding negligence that justified the dismissal of the appeal.

Compliance with Procedural Requirements

In addressing the issue of compliance with the appellate court's procedural rules, the court reaffirmed that timely payment of docket fees is mandatory for perfecting an appeal, as stipulated in the Rules of Court. The failure of the petitioners to pay the docket fees within the required period rendered their appeal improperly perfected, leading the Court of A

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