Samala v. Ocampo
REITERATIONFacts
The Antecedents: On October 19, 1990, a Super Saint Bus, driven by Benjamin Babista and owned by Ildefonso Samala, sideswiped a motorcycle along Panamitan Highway, Kawit, Cavite. Romulo Ocampo, a back rider, was thrown off and sustained serious physical injuries, requiring hospitalization and prolonged treatment. The bus driver did not stop to render assistance. Procedural History: Romulo Ocampo filed a complaint for damages against Babista and Samala. The Regional Trial Court (RTC), Branch 15, Naic, Cavite, rendered a decision on May 15, 1995, in favor of Ocampo, ordering the defendants to pay actual, consequential, loss of earning, moral, exemplary damages, attorney's fees, and litigation expenses, jointly and solidarily. Petitioners filed a notice of appeal on October 16, 1995, which the RTC denied on October 17, 1995, for being filed beyond the 15-day reglementary period. Petitioners filed a petition for relief from the order denying their appeal, citing the illness of Jose Samala, Jr. who was entrusted with filing the notice of appeal, as the reason for the one-day delay. The RTC denied this petition on February 21, 1996. Petitioners appealed these orders to the Court of Appeals (CA). Meanwhile, the RTC granted Ocampo's motion for a writ of execution on March 20, 1996. The RTC denied petitioners' motion for reconsideration of this order on July 1, 1996. Petitioners then filed a petition for certiorari and prohibition with the CA assailing the denial of their petition for relief. The CA denied this petition on September 17, 1996, and subsequently denied their motion for reconsideration. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, assailing the CA's decision denying their petition for relief from the order denying their appeal.
Issue(s)
Whether the Court of Appeals erred in refusing to grant petitioners relief from the order that denied their appeal from the judgment of the trial court. Whether the one-day delay in filing the notice of appeal constitutes excusable negligence.
Ruling
The petition is GRANTED. The decision of the Court of Appeals in CA-G. R. SP No. 41281 is REVERSED. The trial court is ordered to elevate the records of Civil Case No. NC-346 to the Court of Appeals for review in due course of appeal.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in refusing to grant petitioners relief from the order that denied their appeal: The Supreme Court held that the Court of Appeals erred in denying the petition for relief. The Court emphasized that procedural rules are designed to facilitate the administration of justice and should not be used to defeat it. Strict adherence to technicalities that hinder substantial justice must be avoided. The Court found that the one-day delay in filing the notice of appeal was due to excusable negligence, considering the circumstances presented. On the issue of whether the one-day delay in filing the notice of appeal constitutes excusable negligence: The Supreme Court ruled in the affirmative. The Court noted that the delay was for only one day, as the last day to file fell on Friday, October 13, 1995, and the notice was filed on Monday, October 16, 1995. The delay was attributed to the illness of Jose Samala, Jr., who was entrusted with filing the notice. He suffered from diarrhea on October 11-12, 1995, and filed the notice on the next business day, believing in good faith that the period had not yet lapsed. The Court considered this excusable negligence, drawing parallels to cases where appeals were given due course despite tardiness due to peculiar circumstances. The Court reiterated that the purpose of appeal periods is to prevent unreasonable delay, and where no intent to delay is present, a one-day delay should not justify the denial of an appeal. The Court invoked the principles of justice, equity, and fair play, stating that the law abhors technicalities that impede the cause of justice.
Main Doctrine
A one-day delay in filing a notice of appeal, caused by illness of the person entrusted with its filing, may be considered excusable negligence, warranting the relaxation of procedural rules to promote substantial justice, especially when no intent to delay the administration of justice is attributable to the petitioners.