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PHILIPPINE RABBIT BUS LINES, INC., petitioner, vs. HON. LUDIVICO D.

ARCIAGA, TAURINO SINGSON


AND THE HONORABLE COURT OF APPEALS, respondents.
March 16,1987.

Facts:

On August 24, 1960 Taurino Singson from Cabugao Ilocos Sur suffered multiple serious physical injuries
when the Philippine Rabbit bus crashed against an acacia tree at La union causing him to file a complaint
for contractual tort against the latter. The defendant alleged that the collision was accidental. The trial
then was set on December 23,1965 but upon the motion of both counsels, it was postponed and moved
to February 3 and 4 1966. Then, on October 6,1966 the Court noted that no pre-trial has ever been
conducted so both parties were ordered to agree for a compromise agreement at the office of
Philippine Rabbit in Tarlac. The trial was again postponed to November 14,1966 and then transferred
again on January 20,1967 upon the petition filed by counsel for Phil.Rabbit and moved again to April
29,1967. During the scheduled trial on April 29,1967, only the defendant was present on the said date.
So, the court dismissed the case for non-appearance of the plaintiff.

On July 6,1967 (61 days from receipt of dismissal)Plaintiff Taurino Singson filed a petition for Relief with
an affidavit alleging that he went to the trial but due to engine trouble, he arrived late. The lower court
grant plaintiff’s petition for relief. Philippine Rabbit Bus Lines Inc. filed a motion for reconsideration but
the lower court denied the motion. Afterwhich Philippine Rabbit Bus Lines Inc. again filed a petition for
certiorari and mandamus for preliminary injunction in the Court of Appeals but C.A denied the motion.
The company moved for reconsideration but it was also denied.

Issue:

Whether or not the Court of Appeals erred in applying the rule of equity in the case at bar.

Ruling:

No, no one can invoke equity as a ground for reopening a case if an express provision of law exists which
the remedy can be invoked. The rule is “equity follows the law” this means that there are instances
wherein a court gives remedy, where the law gives none ; but if where a particular remedy is given by
the law and that remedy is bounded and circumscribed by particular rules, it would not be proper for
the court to take it up where the law leaves it and extend it further than the law allows. Thus, the legal
maxim “equity aids the vigilant,not those who slumber on their rights” is applicable to this case.
David Reyes vs. Jose Lim,

G.R. No. 134241 (August 11, 2003)

Facts:

Petitioner David Reyes filed a complaint for annulment of contract and damages against respondents.
The complaint alleged that Reyes as seller and Lim as buyer entered into a contract to sell a parcel of
land located at Pasay City with a monthly rental of P35,000. The complaint claimed that Reyes had
informed Harrison Lumber to vacate the Property before the end of January 1995. Reyes also that if they
failed to vacate by 8 March 1995, he would hold them liable for the penalty of P400,000 a month. It was
also alleged that Lim connived with Harrison Lumber not to vacate the Property until the P400,000
monthly penalty would have accumulated and equaled the unpaid purchase price of P18,000,000.
Keng and Harrison Lumber denied that they connived with Lim to defraud Reyes, and that Reyes
approved their request for an extension of time to vacate the Property due to their difficulty in finding a
new location for their business.

Harrison Lumber claimed that it had already started transferring some of its merchandise to its new
business location in Malabon.Lim filed his Answer stating that he was ready and willing to pay the
balance of the purchase price. Lim requested a meeting with Reyes through the latter’s daughter on the
signing of the Deed of Absolute Sale and the payment of the balance but Reyes kept postponing their
meeting. Reyes offered to return the P10 million down payment to Lim because Reyes was having
problems in removing the lessee from the Property. Lim rejected Reyes’ offer and proceeded to verify
the status of Reyes’ title to the Property. Lim learned that Reyes had already sold the Property to Line
One Foods Corporation Lim denied conniving with Keng and Harrison Lumber to defraud Reyes. Reyes
filed a Motion for Leave to File Amended Complaint due to supervening facts. These included the filing
by Lim of a complaint for estafa against Reyes as well as an action for specific performance and
nullification of sale and title plus damages before another trial court.

The trial court granted the motion. In his Amended Answer Lim prayed for the cancellation of the
Contract to Sell and for the issuance of a writ of preliminary attachment against Reyes. The trial court
denied the prayer for a writ of preliminary attachment. Lim requested in open court that Reyes be
ordered to deposit the P10 million down payment with the cashier of the Regional Trial Court of
Parañaque. The trial court granted this motion. Reyes filed a Motion to Set Aside the Order on the
ground the Order practically granted the reliefs Lim prayed for in his Amended Answer. The trial court
denied Reyes’ motion. The trial court denied Reyes’ Motion for Reconsideration. In the same order, the
trial court directed Reyes to deposit the P10 million down payment with the Clerk of Court. Reyes filed a
Petition for Certiorari with the Court of Appeals and prayed that the orders of the trial court be set aside
for having been issued with grave abuse of discretion amounting to lack of jurisdiction. But the Court of
Appeals dismissed the petition for lack of merit..

Issue:

Whether or not the equity jurisdiction is an applicable law on the matter


Ruling:

Yes, The instant case, the Supreme Court held that if this was a case where there is hiatus in the law and
in the Rules of Court. If this case was left alone, the hiatus will result in unjust enrichment to Reyes at
the expense of Lim. Here the court excercised equity jurisdiction.The purpose of the exercise of equity
jurisdiction in this case is to prevent unjust enrichment and to ensure restitution so that substantial
justice may be attained in cases where the prescribed or customary forms of ordinary law are
inadequate.
The Supreme Court also state that rescission is possible only when the person demanding rescission can
return whatever he may be obliged to restore. A court of equity will not rescind a contract unless there
is restitution, that is, the parties are restored to the status quo ante.
In this case, it was just, equitable and proper for the trial court to order the deposit of the P10 million
down payment. The decision of the Court of Appeals.was affirmed.
DR. HECTOR S. RUIZ v. THE HONORABLE COURT OF APPEALS, THE REGISTER OF DEEDS, Iba, Zambales,
RODOLFO V. SIOJO, ANGEL AL. CALUNTAD

G.R. No. 93454 (September 13, 1991)

Facts:

On August 23, 1988, Petitioner Dr. Hector S. Ruiz filed before the CA a complaint for Annulment of
Decision, Documents, Surrender of Owner's Duplicate of Title, Damages with Preliminary Injunction
against respondent Siojo. In March 1979, he appointed Siojo as agent sell the property for P3.5 M After
one year, without Siojo selling the property, Ruiz entered into an agreement with one Mr. Francisco
Joaquin to develop the Magalawa Island However, it didn’t happen, Ruiz then demanded the return of
the owner's duplicate copy of the TCT. The latter refused which prompted Ruiz to file a replevin suit
before the RTC Zambales, in which a judgment was rendered in favor of Ruiz

On or about February 23, 1983, Ruiz executed a Deed of Absolute Sale in favor of herein Siojo to
hamper Mr. Joaquin in holding TCT, On March 1983, respondents Siojo and Caluntad convinced
petitioner Ruiz to file a replevin suit to foreclose any right which Mr. Joaquin may have over the
property. However, he was not informed of the status of the case, a judgment was rendered in their
favor, and through misrepresentations, succeeded in getting TCT No. 25102 to the damage and
prejudice of Ruiz in the amount of P1 M.

On May 28, 1985, Ruiz sold the property to Mr. Christian M. Prohn; Siojo, upon learning of the sale siojo
pleaded for the return of the P200,000.00 to which Ruiz agreed. A Deed of Reconveyance was executed
by Siojo in favor of Ruiz. That unknown to Ruiz, respondents, by conniving with one another, succeeded
in getting TCT No. 25102. It was only upon his inquiry at the Supreme Court that he learned that the title
to the property has been delivered to the respondent.Due to respondent Siojo's refusal to return the
TCT No. 25102, Ruiz filed the replevin case before the RTC Zambales

On petitioner's motion, the respondent Court of Appeals gave petitioner until August 22, 1989 to file his
amended petition On September 21, 1989, petitioner's amended petition was admitted, the same
having been filed within the period granted by the Court. Respondents were required to answer the
amended petition Respondents filed a Motion for Reconsideration of the September 21, 1989
Resolution of respondent Court of Appeals on October 12, 1989 pointing out that the petition was filed
out of time and that Ruiz was directed to implead the trial court that rendered the decision sought to be
annulled but he also impleaded Atty. Jambora which is in violation to Rule 10 of the Rules of Court On
October 20, 1989, respondent Court of Appeals required petitioner to comment on respondent Siojo's
Motion for Reconsideration. Ruiz filed an Urgent Motion for Extension of Time to Comment wherein he
stated that respondent's Motion for Reconsideration is pro-forma, hence on the basis of the time-
honored principle of law — res ipsa loquitur — submitted the incident for resolution

On February 28, 1990, respondent Court of Appeals dismissed the case for late filing of the amended
petition; and for petitioner's failure, among other things, to file his opposition or comment on
respondents' motion for reconsideration dated October 12, 1989 despite being required to do so
Issue:

Whether or not the Court of Appeals erred in applying the rule of equity in the case at bar.

Ruling:

No, It is well settled that litigations should, as much as possible, be decided on their merits, and not on
technicalities, and that every party litigant must be afforded the amplest opportunity for the proper and
just determination of his case, free from unacceptable plea of technicalities. This Court, in the exercise
of equity jurisdiction, may disregard technicalities in order to resolve the case on its merits based on
evidence
Heirs of rodolfo crisostomo (euprocinia, royce and irish crisostomo) v. Rudex international
development corporation.

G.R. No. 176129(August 24, 2011)

Facts:

On December 17, 2001, the Crisostomo spouses bought a property developed by the respondentsy
priced at ₱833,000.00 on installment basis. On February 10, 2002, the Crisostomo family moved in to
their new house; however, they started to notice several construction defects on the house and
inadequate facilities in the subdivision. Thus, on March 22, 2002, the late Rodolfo asked his wife
Euprocinia to discontinue paying their monthly amortizations and to ask for a rescission of the contract.

The HLURB conducted an ocular inspection in Patricia South Villa on March 12, 2003 and found Rodolfos
allegations to be supported by its findings. The HLURB held that under Section 20 of Presidential Decree
No. 957, its findings justified the right of Rodolfo to demand rescission of his contract with the
respondent.

On August 26, 2003, the respondent asked the HLURB to review its July 7, 2003 Decision. It
alleged that Rodolfos allegations were concocted to get out of their contract because he could no longer
pay his monthly amortizations on the property. On August 17, 2004, the HLURB rendered a Decision on
respondents Petition for Review,

This was appealed by the petitioners, who substituted Rodolfo upon his death, to the Office of the
President. On November 18, 2005, which they obtain a favorable decision

On September 15, 2006, the petitioners filed their Petition for Review before the Court of Appeals.
However, this was dismissed outright in a Resolution for being filed out of time, the deadline being
September 14, 2006. The Court of Appeals said that the petitioners were already granted a 15-day
extension and yet no justification or reason was given to explain why they still filed beyond the
extended period.

Issue:

Whether or not the Court of Appeals erred in applying the rule of equity in the case at bar

Ruling:

Yes, We shall limit our discussion to the core issue of whether or not the Court of Appeals erred in
dismissing The petitioners are claiming that their one-day delay in filing their petition before the Court
of Appeals constitutes excusable negligence in the absence of an intent to delay the administration of
justice.

The rules of procedure are mere tools designed to facilitate the attainment of justice. Their strict and
rigid application especially on technical matters, which tends to frustrate rather than promote
substantial justice, must be avoided. Even the Revised Rules of Court envision this liberality.
Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and
chief enemy, deserves scant consideration from the courts.

ILDEFONSO SAMALA AND BENJAMIN BABISTA, vs. THE HON. COURT OF APPEALS,

G.R. No. 128628(August 23, 2001)

Facts:

On October 19, 1990, at about 8:00 p.m., Super Saint Bus with plate number NKJ 468 and body number
975 sideswiped a Yamaha motorcycle with plate number MCGB 5256, along Panamitan Highway, Kawit,
Cavite. Romulo Ocampo was riding at the back of the motorcycle driver. As a result of the impact,
Ocampo was thrown several meters away and landed on a concrete highway causing serious physical
injuries on his neck and left leg. He was confined at the Perpetual Help Hospital for three days and had
several months of treatment. After hitting the motorcycle, the bus sped away. The driver, Benjamin
Babista, did not even lend assistance to the victim and left the victim on the highway.

On December 20, 1990, Romulo Ocampo filed with the Regional Trial Court, Cavite, Branch 15, Naic, a
complainti for damages against driver Benjamin Babista and the owner of the Super Saint Bus, Ildefonso
Samala.After due trial, on May 15, 1995, the trial court rendered a decision in favor of respondent
Ocampo,

On October 16, 1995, petitioners filed with the trial court a notice of appeal.On October 17, 1995, the
trial court denied the appeal. We quote: This refers to the Notice of Appeal received and filed on 16
October 1995. The decision sought to be appealed was received on 29 September 1995. It is clear that
more than 15 days had elapsed; hence, the decision is now final.

On November 24, 1995, petitioners filed with the trial court a petition for relief from order denying their
appeal. Petitioners argued that the reason for the failure to file the notice of appeal within fifteen (15)
days was the fact that the notice was entrusted to Jose Samala, Jr. but he suffered from diarrhea on
October 11 to 12, 1995. He could not leave the house and nobody could attend to the filing of the
notice. Thus, he filed it only on Monday, October 16, 1995, thinking that the period had not lapsed.

Issue:

whether the Court of Appeals erred in refusing to grant petitioners relief from order that denied their
appeal from the judgment of the trial court and erred in applying equity jurisdiction

Ruling:

Yes, We said that the general aim of procedural law is to facilitate the application of justice to the rival
claims of contending parties, bearing in mind that procedural rules are created not to hinder or delay
but to facilitate and promote the administration of justice. In rendering decisions, courts must not be
too dogmatic. A complete view must be taken in order to render a just and equitable judgment.ii[18] It
is far better to dispose of a case on the merits, which is a primordial end, than on technicality that may
result in injustice

The rules of procedure are mere tools designed to facilitate the attainment of justice. Their strict and
rigid application especially on technical matters, which tends to frustrate rather than promote
substantial justice, must be avoided. Even the Revised Rules of Court envision this liberality.
Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and
chief enemy, deserves scant consideration from the courts.

We are inclined to give the same consideration in this case in light of the rules on justice, equity and fair
play. After all, the petition embodied circumstances that warrant heeding the petitioners' plea for
justice. The law abhors technicalities that impede the cause of justice.