Lascano v. Universal Steel Smelting Co., Inc.
REITERATIONFacts
The Antecedents: Armando Lascano (petitioner) entered into a construction project requiring steel bars, which he ordered from Universal Steel Smelting Co., Inc. (USSCI). Petitioner received steel bars valued at P104,268 on August 30, 1990, but subsequently denied ordering them from USSCI. USSCI filed a criminal complaint for estafa, which was dismissed by the Quezon City Prosecutor's Office and later by the Department of Justice. Concurrently, news articles were published in the Manila Bulletin and Tempo, identifying petitioner as a school owner facing an estafa rap. Procedural History: Petitioner filed a complaint for damages against USSCI and its Vice-President, Reynaldo Lim, for malicious prosecution and for causing the publication of the estafa case. The Regional Trial Court (RTC) of Quezon City dismissed petitioner's complaint on December 27, 1994, and ordered petitioner to pay USSCI P104,268 plus interest, P100,000 for moral damages, P50,000 for exemplary damages, P35,000 for attorney's fees, and costs. Petitioner appealed this decision, but the Court of Appeals (CA) dismissed the appeal on August 13, 1998, for failure to pay docket fees. This CA resolution became final and executory. Subsequently, USSCI filed a motion for execution of the RTC judgment, which the RTC granted on February 9, 2000. Petitioner's motion for reconsideration of this order was denied on April 28, 2000. Petitioner then filed a special civil action for certiorari with the CA, which was dismissed on August 7, 2000, due to late filing. The CA denied petitioner's motion for reconsideration on November 15, 2000. The Petition: Petitioner filed the instant petition before the Supreme Court, assailing the CA's resolutions dismissing his special civil action for certiorari. He argues that the CA erred in strictly applying the rules on filing deadlines, contrary to the liberal construction rule, and in disregarding the interest of justice and equity. Petitioner contends that the RTC decision subject to execution was unjust and void. The Supreme Court, in its review, found merit in the procedural aspect, applying Supreme Court Circular No. 56-2000 retroactively. This circular dictates that the 60-day period to file a certiorari petition is counted from the notice of denial of a motion for reconsideration. Under this rule, petitioner's filing on July 31, 2000, was timely. The Court then proceeded to resolve the merits of the case, modifying the damages awarded by the RTC.
Issue(s)
Whether the Court of Appeals gravely erred in strictly applying the rules in the filing of a petition for certiorari contrary to the liberal construction rule, disregarding the interest of justice and equity. Whether the RTC gravely abused its discretion in granting the writ of execution, upholding that it is the ministerial duty of the court to issue the writ, and that execution will put to rest the controversy; and whether the RTC gravely abused its discretion in disregarding the rule that a writ of execution may be disallowed on equitable grounds; specifically, whether the RTC decision subject of execution was allegedly unjust and void. Whether the counterclaims filed by the private respondents were compulsory or permissive.
Ruling
The Supreme Court set aside the resolutions of the Court of Appeals dismissing the petition for certiorari on the ground of late filing. The Court affirmed the RTC's decision dated December 27, 1994, except for the amounts of moral and exemplary damages, which were modified and reduced. The Court ruled that the counterclaims were compulsory, and thus, non-payment of docket fees did not affect the RTC's jurisdiction.
Ratio Decidendi
On the timeliness of the petition for certiorari: The Court held that the Court of Appeals erred in dismissing the petition for certiorari on the ground of late filing. Applying Supreme Court Circular No. 56-2000, the 60-day period should be counted from the receipt of the order denying the motion for reconsideration. The Court reiterated the principle that remedial statutes are generally retroactive and apply to pending cases. The Court found that the CA's strict application of the rules, disregarding the interest of justice and equity, was erroneous. On the merits of the RTC's decision and the writ of execution: The Court found no error in the RTC's dismissal of the petitioner's complaint for damages. The delivery of steel bars was established by a preponderance of evidence, justifying the order to pay their value. The petitioner's unjustified refusal to pay a just debt warranted moral damages under Article 2220 of the Civil Code, applicable only to the individual respondent, Reynaldo Lim. Exemplary damages were in order as a consequence of the moral damages. The Court modified the amounts of moral and exemplary damages, reducing them to ₱10,000.00 and ₱5,000.00, respectively, considering the amount of the unpaid debt. On the nature of the counterclaims: The Court ruled that the counterclaims filed by the private respondents were compulsory, not permissive. A compulsory counterclaim arises out of or is connected with the transaction or occurrence constituting the subject matter of the opposing party's claim and does not require the presence of third parties. The alleged malicious filing of estafa was necessarily connected with the non-payment of the steel bars. Therefore, the non-payment of docket fees did not affect the jurisdiction of the RTC to rule on these compulsory counterclaims.
Main Doctrine
Procedural laws, including amendments to rules on filing periods, are generally retroactive and apply to pending cases, provided no vested rights are impaired. The period to file a petition for certiorari is interrupted by a timely motion for reconsideration, and the remaining period resumes from notice of denial.