Manila Cordage Company v. Gatmaitan
REITERATIONFacts
The Antecedents: Harry M. Ikdal filed a complaint against Manila Cordage Company (MCC) for breach of contract and damages, alleging MCC's failure to pay him a 5% commission on sales of ropes to Thoresen & Co. during 1956, except for January and March. MCC denied the existence of a sales agency contract, asserting the payments were customary trade discounts. Procedural History: Ikdal filed interrogatories requesting MCC's gross sales figures to Thoresen & Co. MCC objected, claiming the questions were already answered and irrelevant. The trial court ordered MCC to answer. MCC's amended answer provided sales data for specific invoices but did not fully comply with the monthly sub-totals requested. Ikdal moved to strike the answer, hold MCC in contempt, and declare it in default. The trial court declared MCC in default on July 23, 1959, finding the answer did not meet the interrogatory's requirements. MCC's motion for reconsideration was denied. A subpoena duces tecum was issued for MCC's president. MCC's motions to postpone were denied, and Ikdal presented evidence ex parte. MCC filed an original action for certiorari and prohibition with preliminary injunction with the Supreme Court (G.R. No. L-15883) to review the default order, which was dismissed for lack of merit. Upon return to the trial court, Ikdal presented further evidence. Judge Froilan Bayona retired, and the case was reassigned to Judge Gatmaitan. Judge Gatmaitan rendered a decision ordering MCC to pay Ikdal P2,348.92 plus interest, P250 for accountant expenses, and attorney's fees. A writ of execution was issued on July 7, 1960. MCC filed a motion to dissolve the writ, which was temporarily stayed. MCC then filed the present petition for certiorari and prohibition. The Petition: MCC filed a petition for certiorari and prohibition, questioning the declaration of default and the subsequent judgment.
Issue(s)
Whether the trial court committed grave abuse of discretion in declaring petitioner Manila Cordage Company in default. Whether the issues raised in the present petition for certiorari are identical to those previously raised and dismissed by the Supreme Court in G.R. No. L-15883.
Ruling
The Supreme Court dismissed the petition for certiorari and dissolved the preliminary injunction. The Court held that the issues raised in the present petition were identical to those previously determined in G.R. No. L-15883, which was dismissed for lack of merit, and found no new grounds to warrant a modification of its prior resolution. The Court reiterated its holding that such repetitive petitions are intended to mislead or delay legal proceedings.
Ratio Decidendi
On the issue of whether the trial court committed grave abuse of discretion in declaring petitioner Manila Cordage Company in default: The Court found that the answer provided by Manila Cordage Company to the interrogatory did not fully meet the requirements thereof. The trial court, after examining the answer and finding it insufficient, issued an order declaring the defendant in default. This action was taken after the defendant failed to obtain a reconsideration of the order. The subsequent filing of a petition for certiorari and prohibition (G.R. No. L-15883) to challenge this default order was dismissed by the Supreme Court for lack of merit. Therefore, the declaration of default was a procedural consequence of the insufficient answer and the subsequent dismissal of the challenge to that order. On the issue of whether the issues raised in the present petition for certiorari are identical to those previously raised and dismissed by the Supreme Court in G.R. No. L-15883: The Supreme Court explicitly stated that the matters treated in the present petition are "basically identical" to those raised and determined in the prior case, G.R. No. L-15883. The Court noted that there were "no new grounds or issues alleged that would merit a modification of our resolution of dismissal." The Court further emphasized its stance against repetitive petitions, stating that they are "apparently intended either to mislead the Court or to delay legal proceedings." Consequently, the Court reiterated its holding from the previous dismissal, finding no basis to grant the current petition.
Main Doctrine
A petition for certiorari will be dismissed for lack of merit if it raises issues identical to those previously determined by the Supreme Court in a prior similar petition involving the same parties and issues, without alleging new grounds.