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ILDEFONSO SAMALA v. CA

FACTS:

On October 19, 1990, a bus owned by Ildefonso Samala and driven by Benjamin Babista sideswiped a motorcycle driven by Romulo Ocampo along Panamitan Highway, Kawit, Cavite. Ocampo was thrown several meters away and suffered serious physical injuries. After the accident, the bus driver fled the scene without rendering assistance to the victim. Ocampo filed a complaint for damages against the bus driver and owner with the Regional Trial Court (RTC) of Cavite. After trial, the RTC rendered a decision in favor of Ocampo, ordering the defendants to pay various amounts for damages, including actual damages, consequential damages, loss of earning, moral damages, exemplary damages, attorney's fees, and litigation expenses. The defendants filed a notice of appeal with the RTC, but it was denied on the ground that the decision had become final as more than 15 days had lapsed. The defendants then filed a petition for relief from the order denying their appeal, stating that the delay in filing the notice of appeal was due to a medical condition suffered by their representative. The RTC denied the petition for relief, and the defendants filed a notice of appeal with the trial court. The trial court granted Ocampo's motion for a writ of execution, and the defendants filed a motion for reconsideration, which was denied. The defendants then filed a petition for certiorari and prohibition with the Court of Appeals (CA) assailing the denial of their petition for relief. The CA denied the petition, and the defendants filed a motion for reconsideration, which was also denied. Thus, the defendants filed a petition for certiorari with the Supreme Court.

ISSUES:

  1. Whether the Court of Appeals erred in refusing to grant petitioners' relief from the order that denied their appeal from the judgment of the trial court.

RULING:

  1. The petition is granted. The decision of the Court of Appeals is reversed. The trial court is ordered to elevate the records of the case to the Court of Appeals for review in due course of appeal.

PRINCIPLES:

  • Relief from judgment under Rule 38 of the Revised Rules of Court is a remedy provided to any person against whom a decision or order is entered into through fraud, accident, mistake or excusable negligence.

  • The failure to file the notice of appeal on time may be excusable negligence depending on the circumstances of the case.

  • The rules of procedure are mere tools designed to facilitate the attainment of justice.

  • Technicality, when it becomes a hindrance and enemy of justice, deserves scant consideration from the courts.

  • The limitation of the period of appeal is to avoid an unreasonable delay in the administration of justice and put an end to controversies.

  • A one-day delay in filing the notice of appeal may be justified if there was no intent to delay the administration of justice.