De Lima vs. Laguna Tayabas Co.

As an exception to the well-settled rule that a party who does not appeal a judgment cannot obtain affirmative relief, an appellate court may, on equitable grounds, modify the judgment in favor of the non-appealing party, especially when said party is an indigent litigant, the opposing party's appeal is dilatory, and substantial justice would otherwise be denied due to procedural technicalities.

The case originated from a vehicular collision on June 3, 1958, between a passenger bus owned by Laguna Tayabas Bus Co. (LTB) and a delivery truck of the Seven-Up Bottling Co. The incident resulted in the death of Petra de la Cruz and serious physical injuries to Eladia de Lima and Nemesio Flores, who were all passengers of the LTB bus. This led to the filing of three separate civil suits for damages against the respondents, which were consolidated for trial.

• On June 3, 1958, a collision between a bus of Laguna Tayabas Co. (LTB) and a Seven-Up Bottling Co. truck caused the death of passenger Petra de la Cruz and serious injuries to passengers Eladia de Lima and Nemesio Flores.
• Three consolidated civil cases were filed against the respondents in the Court of First Instance (CFI) of Laguna.
• On December 27, 1963, the CFI found LTB and its driver jointly and severally liable, awarding various amounts for damages, including P3,000 as indemnity for the death of Petra de la Cruz, but without awarding legal interest.
• The plaintiffs (now petitioners) filed a motion for reconsideration with the CFI to include legal interest, but the court failed to act on this motion.
• Citing financial necessity, the plaintiffs desisted from appealing the decision, hoping for immediate payment from the defendants.
• Only the defendants, LTB Co. and its driver, appealed the CFI decision to the Court of Appeals.
• While the case was pending on appeal, the petitioners filed a motion with the Court of Appeals on December 29, 1971, praying for legal interest to be computed from the date of the CFI decision and for the death indemnity to be increased to P12,000.
• On January 31, 1972, the Court of Appeals affirmed the CFI's decision but modified it to include legal interest, ruling that such interest should only run from the date of its own decision, not the CFI's. It did not increase the death indemnity.
• The Court of Appeals denied the petitioners' subsequent motion for reconsideration, reasoning that since the petitioners did not appeal, they could not be granted further affirmative relief.

• The Court of Appeals erred in ruling that the legal interest on the awarded damages should commence only from the date of its own decision (January 31, 1972) instead of from the date of the trial court's decision (December 27, 1963), which contravenes established jurisprudence.
• The Court of Appeals erred by not increasing the civil indemnity for the death of Petra de la Cruz from P3,000.00 to P12,000.00 to align with the prevailing legal standard at that time.

• The petitioners are precluded from questioning the judgment and seeking affirmative relief, such as an earlier start date for interest or an increased indemnity, because they did not appeal the decision of the lower court.

• Procedural Issues:
  • Whether a party who did not appeal from a judgment can be granted affirmative relief by the appellate court.
• Substantive Issues:
  • Whether the legal interest on the damages awarded should be computed from the date of the trial court's decision or the Court of Appeals' decision.
  • Whether the civil indemnity for death should be increased from P3,000.00 to conform with prevailing jurisprudence.

• Procedural:
  • Yes, the Court can grant affirmative relief to a non-appealing party as an exception to the general rule. The Court adopted a liberal stance, citing that the petitioners were litigating as paupers, had filed an unacted-upon motion for reconsideration in the trial court, and that the respondents' appeal was dilatory and oppressive. Given the case had been pending for 30 years, the Court found that denying relief on a procedural technicality would result in a denial of substantial justice, and thus afforded the petitioners equitable relief.
• Substantive:
  • The legal interest of six percent (6%) on the adjudged amounts should start from the date of the trial court's decision on December 27, 1963, until actual payment, in line with consistent Supreme Court rulings. The Court took exception to the appellate court's ruling on this matter.
  • The civil indemnity for the death of Petra de la Cruz is increased from P3,000.00 to P30,000.00. The Court found this increase justified under Articles 1764 and 2206 of the Civil Code and was in accordance with the prevailing jurisprudence at the time of its ruling.

• General Rule on Appeals by Non-Appellants — A party who does not appeal from a decision may not obtain any affirmative relief from the appellate court other than what was obtained from the lower court. The Supreme Court acknowledged this as the well-settled rule but created a specific exception for this case based on equity.
• Liberal Construction of Procedural Rules — Pleadings and remedial laws should be construed liberally to allow litigants ample opportunity to pursue their claims and to prevent the denial of substantial justice due to legal technicalities. This was applied because the petitioners were indigent and had shown intent to pursue their claims for interest and increased indemnity.
• Equitable Relief — Courts have the discretion to grant relief based on justice and equity, especially to protect the rights of the underprivileged and to mitigate the impact of dilatory and oppressive tactics by an opposing party. The Court invoked this principle to justify granting the petitioners' claims despite their failure to appeal.
• Discretionary Award of Interest (Art. 2210, Civil Code) — The doctrine that a court may, in its discretion, allow interest upon damages awarded for breach of contract. The Court of Appeals used this to grant interest, and the Supreme Court used this equitable principle to correct the commencement date of the interest.
• Indemnity for Death in Breach of Contract of Carriage (Arts. 1764 and 2206, Civil Code) — A common carrier is liable for the death of a passenger, and the law provides for a minimum amount of damages. The Court applied this doctrine to increase the death indemnity to P30,000.00, reflecting the prevailing jurisprudential standard.

• "Pleadings as well as remedial laws should be construed liberally in order that the litigants may have ample opportunity to pursue their respective claims and that a possible denial of substantial justice due to legal technicalities may be avoided."
• "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 dilatory and oppressive of the rights of the said claimants; that the case had been pending in court for about 30 years from the date of the accident in 1958 so that as an exception to the general rule aforestated, the said heirs who did not appeal the judgment, should be afforded equitable relief by the courts as it must be vigilant for their protection."

• Itogon-Suyoc Mines, Inc. v. NLRC — Cited to establish the general rule that a party who does not appeal from a judgment cannot seek modification or reversal thereof. The Supreme Court then proceeded to create an exception to this rule for the present case.
• Fores v. Miranda — Referenced to support the appellate court's authority to grant relief (in that case, attorney's fees) to a non-appealing party when it is deemed just and equitable, as such relief can be considered included in the general concept of damages.
• Imperial vs. Ziga; Lopez, et al. vs. Pan American World Airways — Cited as part of a line of "consistent rulings" establishing that legal interest on damages should run from the date of the trial court's decision, not the appellate court's.

• Art. 2210, Civil Code — Cited as the legal basis for the discretionary authority of courts to award interest upon damages for breach of contract, which the Court of Appeals used to grant interest and which the Supreme Court relied on to modify its start date.
• Art. 1764, Civil Code — Cited in relation to Art. 2206 to establish the basis for awarding civil indemnity for the death of a passenger due to a breach of contract by a common carrier.
• Art. 2206, Civil Code — Cited as the provision that allows for a minimum indemnity (which was P3,000.00 at the time) for death, which the Court increased to P30,000.00 based on prevailing jurisprudence.
• Art. 24, Civil Code — Referenced in a footnote, this article pertains to the duty of courts to be vigilant in protecting the rights of those who are disadvantaged in life, underpinning the Court's equitable considerations for the indigent petitioners.