Enecilla v. Magsaysay
REITERATIONFacts
The Antecedents: Petitioner, Servanda Enecilla, a beautician, and respondent, Luz Magsaysay, widow of President Ramon Magsaysay, were old friends. Enecilla provided unsolicited beauty treatments to Magsaysay while the latter was First Lady, out of courtesy and friendship, with neither expecting compensation. Magsaysay reciprocated with favors. Procedural History: Petitioner filed a complaint against respondent for unpaid salaries, damages, and attorney's fees. The Court of First Instance of Manila dismissed the complaint. The Court of Appeals affirmed the dismissal but awarded respondent P2,000.00 as counsel fees and imposed double costs on petitioner. The Petition: Petitioner seeks review of the Court of Appeals' decision, specifically challenging the award of counsel fees, arguing that respondent did not file a counterclaim for such fees in either the trial court or the appellate court, thus waiving the claim.
Issue(s)
Whether the Court of Appeals erred in awarding counsel fees to the respondent despite the absence of a counterclaim for such fees in the lower court or in the appellate court. Whether the imposition of double costs upon the petitioner was justified.
Ruling
The Supreme Court modified the decision of the Court of Appeals by removing the award of counsel fees. The judgment was affirmed in all other respects, including the dismissal of the complaint and the imposition of double costs.
Ratio Decidendi
On the award of counsel fees: The Court found merit in the petitioner's contention that the award of counsel fees by the Court of Appeals was improper. The Court reiterated the principle that an appellee can only advance arguments to defeat the appellant's claim or uphold the lower court's decision, and can assign errors if necessary to strengthen the lower court's views. However, an appellee cannot be granted relief not invoked by her in the appellate court; to deserve such relief, she must herself appeal. The Court distinguished the present case from Fores v. Miranda, where attorney's fees were awarded because the defendant had asked for damages in his answer, and the fees were considered part of those damages. In the instant case, the respondent did not set up any claim for damages or attorney's fees in either court, thus waiving the right to such relief. The award made by the Court of Appeals lacked legal basis. On the imposition of double costs: The Court found the imposition of double costs by the Court of Appeals to be justified. The appellate court had determined that the appeal was frivolous and that the petitioner's theory was "preposterous and absurd" after a careful consideration of the evidence. This finding of fact was beyond the scope of review for the Supreme Court.
Main Doctrine
An award of attorney's fees by an appellate court is not proper if the appellee did not file a counterclaim for damages or attorney's fees in the trial court, nor made any plea therefor in the appellate court, as such relief must be invoked.