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  • MRCA V CA

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    Aljenneth Micaller
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    The Supreme Court ruled that the Manchester decision, which required specifying damage amounts in complaints, applied retroactively including to cases filed before its publication. While the petitioner argued the decision was not yet effective since unpublished, the Court found publication unnecessary for effectiveness and that procedural rules can be applied retroactively. Prior case law also supported retroactive application. Therefore, the Court set aside lower court rulings dismissing the case and allowed amendment and payment of proper fees.

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    The Supreme Court ruled that the Manchester decision, which required specifying damage amounts in complaints, applied retroactively including to cases filed before its publication. While the petitioner argued the decision was not yet effective since unpublished, the Court found publication unnecessary for effectiveness and that procedural rules can be applied retroactively. Prior case law also supported retroactive application. Therefore, the Court set aside lower court rulings dismissing the case and allowed amendment and payment of proper fees.

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    96 views2 pages

    MRCA V CA

    Uploaded by

    Aljenneth Micaller
    The Supreme Court ruled that the Manchester decision, which required specifying damage amounts in complaints, applied retroactively including to cases filed before its publication. While the petitioner argued the decision was not yet effective since unpublished, the Court found publication unnecessary for effectiveness and that procedural rules can be applied retroactively. Prior case law also supported retroactive application. Therefore, the Court set aside lower court rulings dismissing the case and allowed amendment and payment of proper fees.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    of 2

    MRCA v.

    CA
    G.R. No. 86675 12 December 1989 Griño-Aquino, J.
    When do laws take effect and Sef
    Retroactivity
    PETITIONER RESPONDENTS
    MRCA, Inc. Court of Appeals, Hon. Benjamin V.
    Pelyo, Judge, Regional Trial Court,
    National Capital Judicial Region, Branch
    168, Pasig, M.M., Spouses Domingo
    Sebastian, Jr. & Lilia Tioseco Sebastian,
    and Expectacion P. Tioseco
    RECIT-READY SUMMARY
    A petition for certiorari (under Rule 45 of Rules of Court) was filed by the petitioner to
    ask the Court to set aside the decision of the CA that was promulgated on 18 January
    1989. It affirmed the decision of the RTC to dismiss the complaint for non-payment of
    proper filing fees due to the failure to specify the amounts of moral damages, exemplary
    damages, attorney’s fees and litigation expenses sought to be recovered.

    The argument of the Petitioner was that the decision in Manchester (MRCA, Inc. vs.
    Spoused Domingo Sebastian, Jr., et al) had not yet been published in the Official
    Gazette when its complaint was filed, the ruling therein was ineffective. The ruling may
    not be given retroactive effect because it imposes a new penalty for its non-observance.

    However, the Court posited that the publication in the Official Gazette was not a
    prerequisite for the effectivity of the ruling. The ruling becomes effective at once.

    The Manchester ruling was applied retroactively in Sun Insurance Office, Ltd., et al vs
    Asuncion, et al. on 13 Feb 1989. The latter case was already pending before
    Manchester was promulgated.

    The petition for review was granted. The decision of the RTC was set aside.
    FACTS
    1. A decision by the Court of Appeals was promulgated on 18 January 1988,
    wherein the RTC’s decision to dismiss the complaint for non-payment of the
    proper filing fees as the prayer of the complaint failed to specify the amounts of
    moral damages, exemplary damages, attorney’s fees and litigation expenses.
    2. The petitioner prays the petition for review under Rule 45 of the Rules of Court
    to set aside the said decision.
    3. On July 15, 1988, the respondents filed a motion to dismiss the case. They
    invoked the case in MRCA, Inc. vs. Spouses Domingo Sebastian, Jr. et al.
    4. The Petitioner argued that the ruling was ineffective since the decision in
    Manchester had not yet been published in the Official Gazette when its complaint
    was filed.
    ISSUES RULING
    1. Whether or not the Manchester NO
    case is ineffective against the ruling
    because it was not yet published in
    the Official Gazette when the
    complaint was filed.

    2. Whether or not the Manchester YES


    ruling can be applied retroactively
    to this case
    RATIONALE/LEGAL BASIS
    1. The publication of a ruling in the Official Gazette is not a prerequisite for its
    effectivity even if it lays down a new rule of procedure. In Aguillon vs. Director of
    Lands: "it is a doctrine well established that the procedure of the court may be
    changed at any time and become effective at once, so long as it does not affect
    or change vested rights."
    2. The Manchester ruling, which was promulgated on 7 May 1987, can also be
    applied retroactively in this case:
    “It is a well-established role of statutory construction that statutes regulating the
    procedure of the courts will be construed as applicable to actions pending and
    undetermined at the time of their passage. Procedural laws are retrospective in
    that sense and to that extent.”
    3. The Manchester ruling was applied retroactively in Sun Insurance Office, Ltd.,
    et al vs Asuncion, et al. (G.R. Nos. 79937-38) on 13 Feb 1989. The latter case
    was already pending before Manchester was promulgated.
    4. The complaint was filed on 24 March 1988, ten months after Manchester, the
    ruling should apply to this case except that it was modified in the Sun Insurance
    case, where the Court allowed payment of the proper filing fee within a
    reasonable time but in no case beyond the prescriptive or reglementary period.

    DISPOSITIONS
    The Court set aside the CA and RTC ruling. The petitioner was allowed to amend the
    amounts of damages it seeks to recover from the defendants and to pay the proper
    filing fees therefor as computed by the Clerk of Court.

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