[6] De Lima v. Laguna Tayabas Co.

Application to the case: We take note of the fact that petitioners are litigating as
G.R. Nos. L-35697-99| April 15, 1988| Art. 24 | Paula | First Division
paupers. Although they may not have appealed, they had filed their motion for
Petitioner: ELADIA DE LIMA, POTENCIANO REQUIJO, NEMESIO FLORES, REYNALDO reconsideration with the court a quo which unfortunately did not act on it. By reason
REQUIJO, DOMINADOR REQUIJO and MARIO REQUIJO of their indigence, they failed to appeal but petitioners De Lima and Requijo had filed
Respondents: LAGUNA TAYABAS CO., CLARO SAMONTE, SANTIAGO SYJUCO, INC., their manifestation making reference to the law and jurisprudence upon which they
(SEVEN-UP BOTTLING CO., OF THE PHILIPPINES) and PORVENIR ABAJAR BARRETO base their prayer for relief while petitioner Flores filed his brief.
Moreover, under the circumstances of this case where the heirs of the victim in the
Recit-Ready Facts A passenger bus and a delivery truck collided. A passenger (Dela traffic accident chose not to appeal in the hope that the transportation company will
Cruz) died, and 2 others (De Lima and Flores)were seriously injured. Consequently, 3 pay the damages awarded by the lower court but unfortunately said company still
civil suits were filed against the bus company. The lower ruled in favor of the appealed to the Court of Appeals, which step was obviously dilatory and oppressive
of the rights of the said claimants; that the case had been pending in court for about
petitioners and ordered the bus company and its driver to pay solidarily. The
30 years from the date of the accident in 1958 so that as an exception to the general
petitioners then filed a motion for reconsideration seeking an award for legal interest
rule aforestated, the said heirs who did not appeal the judgment, should be afforded
on the amounts adjudged in their favor but it was not acted upon by the court a quo. equitable relief by the courts as it must be vigilant for their protection. 1 The claim for
legal interest and increase in the indemnity should be entertained in spite of the
The petitioners then desisted from appealing the decision by reason of financial failure of the claimants to appeal the judgment.
necessity. Only the defendants appealed to the CA.
FACTS:
Later, the petitioners filed a motion with the CA where they sought for the immediate 1. A passenger bus of LTB and a delivery truck collided. This resulted in the
decision of the case with a prayer for granting the legal interest from the date of the death of 1 passenger (Dela Cruz) and serious physical injuries to 2 other
decision of the court a quo. The CA denied the motion of the petitioners stating that passengers (de Lima and Flores).
the court, on its own, awarded such interest and that it should not be rolled back to 2. Three civils suits were then filed against the respondents.
3. The CFI ordered LTB and the bus driver to pay the 3 plaintiffs solidarily.
the time the lower court decision was rendered.
4. The plaintiffs then filed a motion for reconsideration of the decision
seeking an award of legal interest on the amounts adjudged in their favor.
Respondents now claim that petitioners having failed to appeal from the lower a. But the said decision was not acted upon by the court a quo.
court's decision they are now precluded from questioning the ruling of the Court of 5. All the plaintiffs voluntarily desisted from appealing the decision by reason
Appeals. of financial necessity and in the hope that the defendants LTB Co. and its
driver will be persuaded to make immediate payment to them as adjudged
Issue: WON the Court of Appeals erred in granting legal interest on damages to start by the court a quo.
6. Only the defendants appealed the decision to the Court of Appeals.
only from the date of its decision instead of from the date of the trial court's decision
7. The plaintiffs then filed a motion with the Court of Appeals. They sought
–YES. for an immediate decision of the case with a prayer for the granting of
legal interest from the date of the decision of the court a quo and for the
Doctrine: This Court is inclined to adopt a liberal stance in this case as We have done increase to P12,000.00 of the civil indemnity of P3,000.00 awarded for the
in previous decisions where We have held that litigations should, as much as possible death of one of the passengers.
be decided on their merits and not on technicality. *Art. 24 was also cited in the 1
This paragraph cited Art. 24 of the Civil Code –Art. 24. In all contractual, property or other
relations, when one of the parties is at a disadvantage on account of his moral dependence,
footnotes of the decision
ignorance, indigence, mental weakness, tender age, or other handicap, the courts must be vigilant
for his protection .
 8. The Court of Appeals denied the motion for reconsideration holding that dilatory and oppressive of the rights of the said claimants; that the case had
since the plaintiffs did not appeal from the failure of the court a quo to been pending in court for about 30 years from the date of the accident in 1958
award interest on the damages and that the court on its own discretion so that as an exception to the general rule aforestated, the said heirs who did
awarded such interest should not be rolled back to the time the decision of not appeal the judgment, should be afforded equitable relief by the courts as it
the court a quo was rendered. must be vigilant for their protection. The claim for legal interest and increase in
the indemnity should be entertained in spite of the failure of the claimants to
ISSUES appeal the judgment.
1. Whether or not the Court of Appeals erred in granting legal interest on 7. We take exception to the ruling of the Appellate Court as to the date when the
damages to start only from the date of its decision instead of from the legal interest should commence to run.
date of the trial court's decision –YES. 8. In view of the consistent rulings of this Court, We hold that the legal interest of
2. Whether or not the Court of Appeals erred in not increasing the six percent (6%) on the amounts adjudged in favor of petitioners should start
indemnity for the death of Petra de la Cruz (in Civil Case No. SP-240) from the time of the rendition of the trial court's decision on December 27,
from P3,000 to P12,000.00. 1963 instead of January 31, 1972, the promulgation of the decision of the Court
of Appeals.
RATIO:
2nd issue
We find merit in the petition.
1. As to the second issue, civil indemnity for the death of Petra de la Cruz was
1st issue: properly awarded by virtue of Art. 1764 in relation to Art. 2206 of the Civil
Code of the Philippines which allows a minimum indemnity of P3,000.00 for the
1. Petitioners contend that the ruling of the Appellate Court departs from the death of a passenger caused by the breach of contract by a common carrier. In
consistent rulings of this Court that the award of the legal rate of interest accordance with prevailing jurisprudence the indemnity of P3,000.00 should be
should be computed from the promulgation of the decision of the trial court. increased to P30,000.00 and not P12,000.00 as prayed for by petitioner.
2. Respondents counter that petitioners having failed to appeal from the lower 2. If the transportation company had only accepted the judgment of the trial
court's decision they are now precluded from questioning the ruling of the court and paid its just awards instead of appealing the same to the Court of
Court of Appeals. Appeals, no further delay would have been occasioned on the simple issue of
3. At any rate, this Court is inclined to adopt a liberal stance in this case as We interest and indemnity. To mitigate the impact of such a great delay in this case
have done in previous decisions where We have held that litigations should, as the Court finds ample justification in the aforesaid award for interest and
much as possible be decided on their merits and not on technicality. indemnity. We hope this relief is not too late.
4. We take note of the fact that petitioners are litigating as paupers. Although
they may not have appealed, they had filed their motion for reconsideration
with the court a quo which unfortunately did not act on it. By reason of their
indigence, they failed to appeal but petitioners De Lima and Requijo had filed WHEREFORE, the petition is hereby GRANTED, the subject decision is modified in
their manifestation making reference to the law and jurisprudence upon which that the legal interest on the damages awarded to petitioners commences from the
they base their prayer for relief while petitioner Flores filed his brief. date of the decision of the court a quo until actual payment while the civil
5. Pleadings as well as remedial laws should be construed liberally in order that indemnity for the death of Petra de la Cruz is increased to P30,000.00. This
the litigants may have ample opportunity to pursue their respective claims and judgment is immediately executory and no motion for extension of time to file
that a possible denial of substantial justice due to legal technicalities may be motion for reconsideration shall be entertained.
avoided.
6. Moreover, under the circumstances of this case where the heirs of the victim in
the traffic accident chose not to appeal in the hope that the transportation
company will pay the damages awarded by the lower court but unfortunately
said company still appealed to the Court of Appeals, which step was obviously