Europa v. Hunter Garments Mfg. (Phil.), Inc.
REITERATIONFacts
The Antecedents: Lucrecia Europa, employed as a sample maker by Hunter Garments Manufacturing (Philippines) Incorporated, died on March 9, 1978, after being electrocuted by a high-speed sewing machine assigned to her by the company. Her mother, Lucia Europa, subsequently filed an action for damages against the company based on quasi-delict. Procedural History: The petitioner filed a complaint for damages on July 18, 1980. Summons was served on the company's production manager. As no answer was filed, the respondent was declared in default, and the trial court allowed the petitioner to present evidence ex parte. On April 8, 1981, the trial court rendered a judgment ordering the company to pay various damages. The respondent filed motions for reconsideration and to admit an answer, alleging excusable negligence by an employee, which were denied. The respondent appealed to the Court of Appeals, which set aside the default order and judgment, finding that summons had not been properly served on the company. The petitioner's motion for reconsideration of this decision was also denied. The Petition: This petition for certiorari seeks to annul the Court of Appeals' decision. The petitioner argues that even if the trial court initially lacked jurisdiction, the respondent submitted to its jurisdiction by filing motions for reconsideration and to admit an answer. Furthermore, the petitioner contends that the Court of Appeals erred in not reviewing the evidence and the propriety of the damages awarded by the lower court, given the respondent's appeal. The Supreme Court is asked to reinstate the trial court's decision, with an increase in the indemnity for death.
Issue(s)
Whether the Court of Appeals erred in setting aside the default order and judgment by default, and whether the respondent submitted to the jurisdiction of the trial court despite the alleged improper service of summons. Whether the damages awarded by the trial court were proper.
Ruling
The decision of the Court of Appeals is set aside, and the decision of the lower court is reinstated, with an increase in the indemnity for death to P30,000.00.
Ratio Decidendi
On the issue of jurisdiction and submission to the court's authority: The Supreme Court held that even assuming arguendo that the trial court did not originally acquire jurisdiction over the private respondent due to improper service of summons, the private respondent subsequently submitted to the court's jurisdiction. This submission occurred when the private respondent filed a motion for reconsideration of the judgment by default and a motion to admit an answer, grounding their plea on excusable negligence. By taking these actions, the private respondent acknowledged the trial court's authority over the case, and therefore, the lower court's denial of both motions became binding upon the private respondent. The Court cited Soriano vs. Palacio (12 SCRA 449) in support of this principle. Furthermore, the private respondent's appeal from the judgment by default also constituted a submission to the appellate court's review of the case. On the propriety of damages: The Supreme Court found merit in the petition and proceeded to review the evidence presented and the damages awarded by the lower court. The evidence disclosed that Lucrecia Europa died from electrocution by the sewing machine owned by the private respondent, as confirmed by the autopsy report. The Court found the facts and circumstances of the case pointed to the reasonableness of the damages awarded. The trial court had made an express finding of gross negligence on the part of the private respondent. This finding was based on evidence that there were at least two prior incidents where high-speed sewing machines were grounded, which were brought to the attention of management, yet nothing was done. The company lacked a duly-licensed electrical engineer and its three electricians were inadequate for maintaining machine safety. The management showed apathy towards employee safety, and the company's failure to regularly check or properly maintain the machines was deemed the cause of Lucrecia's death by electrocution. The Court reiterated that in actions based on quasi-delict, all damages that are natural and probable consequences of the act or omission complained of are recoverable, as provided for in Article 2202 of the New Civil Code.
Main Doctrine
A party who files a motion for reconsideration of a default judgment and a motion to admit an answer, even if initially questioning jurisdiction, submits to the jurisdiction of the court, rendering the denial of such motions binding.