Professional Documents
Culture Documents
8.caltex v. Singzon-Aguirre
8.caltex v. Singzon-Aguirre
*
CALTEX (PHILIPPINES), INC., CALTEX PHILIPPINES Respondents, the heirs of the victims of the tragedy, initially instituted
PETROLEUM, CO., INC., CALTEX SERVICES (PHILIPPINES), a class action with the Louisiana Court in December 1988. However,
INC., CALTEX OCEANIC LIMITED, CALTEX INVESTMENT the said court dismissed the case on November 30, 2000 on the ground
AND TRADING LIMITED, CALTEX PETROLEUM of forum non conveniens. It was only on March 6, 2001 that
CORPORATION, CALTRAPORT (FAR EAST) COMPANY, respondents filed an action for damages for breach of contract of
CALTEX TRADING AND TRANSPORT CORPORATION, carriage and quasi-delict with the RTC of Catbalogan, Samar against
CALTEX SERVICES CORPORATION, AMERICAN OVERSEAS petitioners, Sulpicio, Vector Shipping, and Steamship Mutual
PETROLEUM LIMITED, P.T. CALTEX PACIFIC INDONESIA, Underwriting Association, Bermuda Limited. The RTC of
CALTEX PETROLEUM, INC., CALTEX ASIA, LIMITED, Catbalogan, motu proprio dismissed the complaint pursuant to Section
CALIFORNIA TEXAS OIL CORPORATION, CALTEX 1, Rule 9 of the 1997 Rules of Civil Procedure as the respondents’
INTERNATIONAL SERVICES LIMITED, CALTEX OIL cause of action had already prescribed. However, the petitioners as
CORPORATION, CALTEX OIL defendants therein, who were not served with summons, filed a motion
CORPORATION (DELAWARE), CALTEX OIL CORPORATION for reconsideration, alleging that they are waiving their defense of
(NEW YORK), CALTEX OIL PRODUCT COMPANY, CALTEX prescription, among others. The RTC of Catbalogan, however, merely
(OVERSEAS) LIMITED, CALTEX INTERNATIONAL LIMITED, noted the petitioners’ motion.
CALTEX OIL CORP., petitioners, vs. MA. FLOR A. SINGZON-
AGUIRRE, ERNEST SINGZON, CESAR SINGZON AND ALL
THE OTHER PLAINTIFFS-INTERVENORS IN CIVIL CASES The respondents again filed a case with the Louisiana Court which
NOS. 91-59592, 91-59658, AND 92-61026 PENDING BEFORE was again dismissed on the same ground of forum non conveniens.
THE REGIONAL TRIAL COURT OF MANILA, BRANCH 39, Respondents thereafter filed a filed a motion for intervention and a
respondents. Caltex (Philippines), Inc. vs. Singzon-Aguirre, 787 complaint-in-intervention with the pending consolidated cases before
SCRA 73, G.R. Nos. 170746-47 March 9, 2016 the RTC of Manila. Also, codefendants in the consolidated cases,
Sulpicio and Steamship were furnished with a copy of the
Reyes, J.
respondents’ motion to intervene. The RTC of Manila denied the said
Facts: motions the ground of bar by prior judgment and thereby disregarded
petitioners’ unconditional waiver of their defense of prescription.
Caltex chartered M/T Vector, a commercial tanker owned and
operated by Vector Shipping Corporation, Inc., to transport its Issue: Whether or not the court had jurisdiction
petroleum products. On its voyage in December 20, 1987, it figured
into a collision with M/V Doña Paz, an inter-island passenger vessel Held:
owned and operated by Sulpicio Lines, Inc. The collision resulted with Remedial Law; Civil Procedure; Jurisdiction; It is basic that courts
an estimate of about 4,000 casualties. acquire jurisdiction over the persons of defendants or respondents,
by a valid service of summons or through their voluntary abandoned their right to waive the defense of prescription. Caltex
submission.—It is not contested that the petitioners were not served (Philippines), Inc. vs. Singzon-Aguirre, 787 SCRA 73, G.R. Nos.
with summons by the RTC of Catbalogan prior to the motu proprio 170746-47 March 9, 2016
dismissal of the respondents’ complaint. It is basic that courts
acquire jurisdiction over the persons of defendants or respondents,
by a valid service of summons or through their voluntary submission.
Not having been served with summons, the petitioners were not
initially considered as under the jurisdiction of the court. However,
the petitioners voluntarily submitted themselves under the
jurisdiction of the RTC of Catbalogan by filing their motion for
reconsideration. Caltex (Philippines), Inc. vs. Singzon-Aguirre, 787
SCRA 73, G.R. Nos. 170746-47 March 9, 2016
Same; Same; Same; Appeals; Settled is the rule that a party is barred
from assailing the correctness of a judgment not appealed from by
him because the presumption [is] that a party who did not interject an
appeal is satisfied with the adjudication made by the lower court.—
“Settled is the rule that a party is barred from assailing the
correctness of a judgment not appealed from by him” because the
“presumption [is] that a party who did not interject an appeal is
satisfied with the adjudication made by the lower court.” Whether
the dismissal was based on the merits or technicality is beside the
point. “[A] dismissal on a technicality is no different in effect and
consequences from a dismissal on the merits.” The petitioners
attempted to justify their failure to file an action to have the orders of
the RTC of Catbalogan annulled by ratiocinating that the respondents
precluded them from doing so when the latter filed their complaint
anew with the RTC of Manila. This is untenable, as it is clear that the
respondents filed the said complaint-in-intervention with the RTC of
Manila more than a year after the case was ordered dismissed by the
RTC of Catbalogan. Aside from this, the petitioners offered no other
acceptable excuse on why they did not raise their oppositions against
the orders of the RTC of Catbalogan when they had the opportunity
to do so. Thus, the only logical conclusion is that the petitioners