G.R. No. L-17135, December 28, 1961
MANILA CORDAGE COMPANY, petitioner, vs. HON. MAGNO GATMAITAN, ETC., and HARRY M. IKDAL, respondents.

FACTS

Respondent Harry M. Ikdal filed a complaint for breach of contract and damages against petitioner Manila Cordage Company, alleging non-payment of a 5% sales commission on certain rope sales. Petitioner denied the existence of any agency contract, contending the payments were trade discounts. During pre-trial, Ikdal served an interrogatory asking for the total gross sales amount to a specific buyer from January 1956 onward. Petitioner objected, arguing irrelevance and that it had been answered, and later provided an answer listing only four specific transactions where Ikdal had a hand.
Dissatisfied, Ikdal moved to strike the answer and declare petitioner in default for failure to properly answer the interrogatory. The trial court granted the motion, declaring petitioner in default. Petitioner’s motion for reconsideration was denied, and the court issued a subpoena duces tecum for its sales records. Petitioner filed an original action for certiorari (G.R. No. L-15883) with the Supreme Court, which was dismissed for lack of merit. The case was returned to the trial court, where Ikdal presented evidence ex parte. Judge Gatmaitan, to whom the case was reassigned, rendered a default judgment against petitioner, which was subsequently executed.

ISSUE

Whether the trial court committed a grave abuse of discretion in declaring petitioner in default for its alleged failure to sufficiently answer the interrogatory, and whether the default judgment is valid.

RULING

The Supreme Court dismissed the petition. The Court found that the issues raised in the present petition were “basically identical” with those already raised, determined, and passed upon in the earlier case, G.R. No. L-15883 (Manila Cordage Co. vs. Hon. Froilan Bayona, etc., et al.), which had been dismissed for lack of merit. The Court reiterated its holding from that prior resolution, emphasizing that it does not entertain petitions that are mere repetitions of allegations and issues already definitively settled in a previous proceeding involving the same parties.
The legal logic is grounded on the doctrine of finality of judgments and the prohibition against forum-shopping or re-litigating the same cause. The Court viewed the present petition as an attempt to rehash arguments already adjudicated, intended either to mislead the Court or to cause further delay in the execution of a final judgment. Since no new grounds or issues were alleged that would warrant a modification of the prior dismissal, the Court upheld the trial court’s orders and the resulting default judgment. The preliminary injunction was dissolved and the petition was dismissed with costs.