CIVPRO CASES

14. Echegaray v. Secretary of Justice 301 SCRA 96

15. Istipura Jr., v. Judge Lobrego GR No. 226679 August 16, 2017
16. Carpio v. Morales 217126 and 217227 November 10, 2015
17. Fabian v. Desierto GR. No. 129419 September 16, 1998

18. Makati Incorporated Company v. Reyes 561 SCRA 634

The Supreme Court Decision with case number G.R. No. 167403 involves a dispute between Makati
Insurance Co., Inc. (the petitioner) and Rubills International, Inc., Tong Woon Shipping PTE LTD,
and Asian Terminals, Inc. (the respondents). The case revolves around damages arising from a
breach of a contract of carriage. Here are the key points:
1. Parties Involved:
o Petitioner: Makati Insurance Co., Inc.
o Respondents: Rubills International, Inc., Tong Woon Shipping PTE LTD, and Asian
Terminals, Inc.
2. Background:
o The petitioner filed a complaint against the respondents for damages related to a
breach of a contract of carriage.
o The vessel involved was the M/V “Cherry,” which arrived in Manila and unloaded a
shipment of 120MT Red Beans and 153.00MT Cattle Meat Colloid.
o Eighty-four (84) ton bags of the shipment were found to be in apparent damaged
condition.
3. Court Proceedings:
o The Regional Trial Court (RTC) dismissed the petitioner’s Notice of Appeal for being
filed three days beyond the reglementary period.
o The Court of Appeals affirmed the RTC’s decision, leading to this petition for review.
4. Decision:
o The Court of Appeals upheld the RTC’s dismissal of the petitioner’s appeal.
o The generative facts of the case were considered, and the rules were applied strictly.

NEYPES v. COURT OF APPEALS is a significant legal case that introduced a modification to the rule
regarding the counting of the 15-day period for filing an appeal in civil cases. Let’s delve into the
details:
1. Background:
o The case involved the heirs of Mercader, who obtained a favorable judgment at the
lower court and the Court of Appeals (CA).
o Dissatisfied with the decisions rendered, the petitioner appealed to the Supreme
Court via a Petition for Review under Rule 45.
o The petitioner raised several procedural flaws, including jurisdictional issues, denial
of due process, and failure to adhere to the rule of clearly stating facts and laws in the
decisions.
2. Key Points:
o Fresh Period for Appeal: In Neypes, the Supreme Court modified the existing rule. It
categorically set a fresh period of 15 days from the denial of a motion for
reconsideration within which to appeal.
o This means that if a party files a motion for reconsideration after an adverse decision,
and the motion is denied, they have a new 15-day window to file an appeal.
o The purpose of this modification was to ensure fairness and procedural clarity.
3. Significance:
o Neypes clarified the timeline for filing appeals, providing litigants with a more
predictable and consistent approach.
o It addressed concerns related to due process and allowed parties to seek appellate
review without undue procedural hurdles.
In summary, Neypes v. Court of Appeals established a fresh appeal period, emphasizing fairness and
adherence to procedural rules in civil cases

1
19. Pinga v. Heirs of Santiago 494 SCRA 393

The case you’re referring to is G.R. No. 170354. In this case, Petitioner Edgardo Pinga was named as
one of the defendants in a complaint for injunction filed with Branch 29 of the Regional Trial Court
(RTC) in San Miguel, Zamboanga del Sur. The complaint was brought by the Heirs of German
Santiago, represented by Fernando Santiago. The essence of the complaint was that petitioner and
co-defendant Vicente Saavedra had been unlawfully entering the coconut lands of the respondent,
cutting wood and bamboos, and harvesting the fruits of the coconut trees there. The respondents
sought an injunction to prevent these alleged acts of depredation and also requested damages1.
In their Amended Answer with Counterclaim, petitioner and his co-defendant disputed the
respondents’ ownership of the properties in question. They asserted that petitioner’s father, Edmundo
Pinga, had been in possession of the properties since the 1930s. Furthermore, they claimed that as far
back as 1968, the respondents had already been ordered ejected from the properties after a complaint
for forcible entry was filed by the heirs of Edmundo Pinga. It was also alleged that the respondents’
application for free patent over the properties was rejected by the Office of the President in 1971. In
response to the respondents’ forcible re-entry and the filing of the case, the defendants prayed for
various types of damages totaling P 2,100,000 plus costs of suit1.
This case highlights the changes introduced in the 1997 Rules of Civil Procedure, particularly the
explicit proviso that if a complaint is dismissed due to the fault of the plaintiff, such dismissal is
“without prejudice to the right of the defendant to prosecute his counterclaim in the same or in a
separate action.” This innovation was instituted despite previous jurisprudence holding that the
dismissal of the complaint justified the dismissal of the compulsory counterclaim as well. The Court
recognized that the former jurisprudential rule could no longer stand in light of Section 3, Rule 17 of
the 1997 Rules of Civil Procedure12.

2
3
4
20. Gonzalo, Puyat v. Alcaidi GR No. 167952 October 10, 2016
G.R. No. 167952, decided on October 19, 2016, involves a legal dispute between Gonzalo Puyat & Sons,
Inc. (petitioner) and Ruben Alcaide (deceased), represented by Gloria Alcaide, who stands for the farmer
beneficiaries12. The case revolves around issues related to land acquisition and agrarian reform.
Here are the key points from the case:
1. Background: The case centers on an order issued by the Department of Agrarian Reform
(DAR) on June 8, 2001. The DAR order pertained to land acquisition and distribution1.
2. Finality of DAR Order: The petitioner, Gonzalo Puyat & Sons, Inc., sought reconsideration of the DAR
Order. However, the Court ruled that the DAR Order had already attained finality for several
reasons:
o The petitioner’s motion for reconsideration was filed after an order of finality had been
issued by the DAR.
o Even if the petitioner’s counsel received the DAR Order later, it was still deemed served
upon the petitioner due to failure to notify the DAR of counsel’s change of address 1.
3. Due Process Issue: The petitioner argued that the DAR failed to comply with the pre-ocular
inspection requirements of DAR Administrative Order No. 1 of 1998, which allegedly violated the
petitioner’s constitutional right to due process. However, the Court rejected this argument,
emphasizing that the issues raised were already exhaustively considered and resolved in previous
proceedings1.
In summary, the case underscores the importance of procedural compliance and the finality of
administrative orders in agrarian reform matters. The Court upheld the DAR’s decision, emphasizing due
process and adherence to established procedures

5
 PCI Leasing and Finance, Inc. vs. Go Ko, decided on March 31, 2005

In the case of PCI Leasing and Finance, Inc. vs. Go Ko , decided on March 31, 2005, the Supreme Court
Reports Annotated (SCRA) citation is 454 SCRA 5861. The issue revolved around the reglementary period
for filing a petition for certiorari. Here are the key points:
1. Background: Respondents Emily
and Finance, Inc. in the Regional Trial Court of
Cebu. The complaint involved
annulment/reformation of chattel mortgage,
annulment of restructuring agreement, fixing of
correct principal, and injunction.
2. Procedural Issue: PCI
However, the CA dismissed the petition because it
was filed beyond the reglementary period.
3. Retroactivity of Procedural Laws

motion for reconsideration from the 60-day

reglementary period. As petitioners only had the
remaining period of 44 days from October 19, 1998
(when they received a copy of the resolution
denying reconsideration), to file the petition for
certiorari, the filing on December 17, 1998, was
nine (9) days too late.
4. Legal Principle: Statutes regulating the procedure
of courts are applicable to actions pending and
undetermined at the time of their passage.
Procedural laws are retroactive in that sense. No vested rights attach to procedural laws.
5. Conclusion: The petition for review on certiorari was denied due to the late filing.
This case underscores the importance of adhering to procedural rules and the retroactive effect of
procedural laws