Republic v. Central Surety & Insurance
REITERATIONFacts
The Antecedents: The Republic of the Philippines filed a suit against Central Surety & Insurance Company (Surety) and its manager, Casimiro Mangoba. Subsequently, the Surety filed a third-party complaint against Po Kee Kam, Tony Go, Go Siu Eng, and Jao Yan alias Go Liao Lian. Procedural History: The Supreme Court issued a decision on October 26, 1968. Central Surety & Insurance Company filed a motion to modify this judgment, seeking to correct the date of the filing of the complaint, to include specific names of third-party defendants, and to add a clause regarding interest and attorney's fees to the dispositive portion. The Petition: The plaintiff-appellee (Republic) offered no objection to the motion to modify. The counsel for the third-party defendants-appellees failed to file any comment despite being required to do so.
Issue(s)
Whether the Supreme Court should modify its prior decision to correct clerical errors in dates, properly identify all third-party defendants, and include the specific interest and attorney's fees prayed for in the third-party complaint.
Ruling
The Supreme Court granted the motion to modify its decision. The decision was amended to reflect the correct date of filing, include the additional third-party defendants, and incorporate the specified interest and attorney's fees in the dispositive portion.
Ratio Decidendi
On Issue 1: The Supreme Court found the Surety's motion to modify the judgment meritorious because the requested corrections were clearly sustained by the evidence in the record. The Court emphasized that the Republic of the Philippines (Republic), acting as the plaintiff-appellee, offered no objection to these modifications, acknowledging that the Surety's assertions were accurate and borne out by the documentation. By correcting the filing date to June 20, 1963, the Court ensured that the procedural history of the case was factually precise and reflected the actual start of the litigation. Additionally, the specific naming of Go Siu Eng and Jao Yan as third-party defendants was necessary to ensure that the judgment could be properly executed against all parties who were part of the third-party complaint. Finally, the inclusion of 12% compounded quarterly interest and 15% attorney's fees was crucial, as these were specific prayers in the original third-party complaint that had been substantiated during the proceedings but omitted from the initial dispositive portion. This modification aligns the final order with the reliefs sought and proved, upholding the principle that the dispositive portion should comprehensively address the prayers of the parties when supported by the record.
Main Doctrine
The Supreme Court may modify its judgment upon finding the grounds of a motion to modify meritorious and sustained by the record, especially when the opposing party offers no objection and the third-party defendants-appellees fail to comment.