Case Summary (G.R. No. 138777)
Applicable Law
The legal framework relevant to this case includes the 1987 Philippine Constitution, the Rules of Court, particularly Rule 9 on default judgments, and Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act.
Background of the Case
On May 30, 1995, a criminal complaint was filed against Salic B. Dumarpa for malversation of public funds, stemming from allegations related to catering services provided by Joy G. Tan. Subsequently, Dumarpa filed a libel complaint against Tan following the publication of her affidavit, which led to a civil case for damages against her. Tan responded by filing a motion to dismiss the civil complaint, asserting that her affidavit was absolutely privileged.
Judgment by Default
During the course of the civil proceedings, the trial court declared Tan in default due to her failure to appear at the pre-trial conference, which she contested, citing inadequate notice. The court subsequently rendered a judgment by default in favor of Dumarpa, awarding him substantial damages.
Motion for Reconsideration and Court's Denial
Tan filed a motion for reconsideration against the judgment by default, arguing that her counsel did not receive proper notice of the pre-trial. However, the trial court denied this motion on procedural grounds, stating that it was pro forma and failed to specify any erroneous findings.
Petition for Review on Certiorari
Tan then elevated the matter to the Supreme Court through a petition for review on certiorari, questioning the propriety of the civil suit filed by Dumarpa prior to the resolution of the libel complaint and the applicability of the privileged communication doctrine to her affidavit.
Supreme Court's Decision
The Supreme Court ultimately allowed Tan's petition, identifying grave abuse of discretion on the part of the trial court. The Court emphasized the principle that cases should be re
...continue readingCase Syllabus (G.R. No. 138777)
Case Overview
- This case revolves around a petition for review on certiorari filed by Joy G. Tan (petitioner) against Salic B. Dumarpa (respondent).
- The petition challenges the Judgment by Default dated January 28, 1999, and the Order dated May 3, 1999, issued by the Regional Trial Court, Branch 9, Marawi City.
- The underlying issue pertains to a civil case for damages filed by Dumarpa against Tan, following accusations of libel related to an affidavit Tan executed.
Factual Background
- On May 30, 1995, a criminal complaint for malversation of public funds was filed against Dumarpa by Prosecutor Ortillano D. Tan.
- Joy G. Tan was engaged as a caterer for a seminar and received payments, after which she issued a receipt.
- Dumarpa allegedly obtained another receipt from Tan to cover a cash advance, which led to the accusations of malversation.
- In response to the publication of Tan's affidavit in several newspapers, Dumarpa filed a criminal complaint for libel against her and then a civil case for damages.
Procedural History
- Joy G. Tan filed a motion to dismiss the civil complaint, arguing that her affidavit was abso