Liclican v. Arranz
REITERATIONFacts
The Antecedents: Brigida Tomas filed an action for forcible entry and detainer against Mariano Liclican, Dionisia Castrog, and Isabel Castrog in the justice of the peace court of Cordon, Isabela. The defendants filed an answer with a counterclaim. Procedural History: The justice of the peace court rendered judgment ordering the defendants to deliver the property and pay damages. The defendants appealed to the Court of First Instance (CFI), and the record was transmitted. Upon receipt of notice that the case was docketed in the CFI, the defendants submitted their answer, stating they were reproducing the answer previously filed in the justice of the peace court, which was attached to the record. The Petition: The defendants filed a motion for postponement of the hearing due to their attorney's illness, attaching a medical certificate. The CFI denied the motion for postponement and, on the same date, entertained the plaintiff's motion for default, declaring the defendants in default for failing to file their answer within the reglementary period. The defendants filed a motion for reconsideration, arguing their reproduced answer was sufficient, but it was denied. They then filed the present petition for certiorari.
Issue(s)
Whether the manifestation filed by the petitioners reproducing their answer from the justice of the peace court is sufficient compliance with the Rules of Court to prevent them from being declared in default.
Ruling
The petition for certiorari is granted. The respondent Judge committed a grave abuse of discretion in declaring the petitioners in default.
Ratio Decidendi
On Issue 1: The Supreme Court held that the filing of a formal answer in the Court of First Instance (CFI) is not necessary when the defendant has already filed a written answer in the justice of the peace court and manifests its reproduction. While Section 7, Rule 40 of the Rules of Court specifically mentions that only the complaint is deemed reproduced, this does not preclude the reproduction of the answer through proper manifestation. The Court reasoned that requiring a party to file a new answer that is identical to the one already in the records would be a 'useless formality.' The Court clarified its previous ruling in Canaynay v. Tan (1949), noting that while the answer is not automatically reproduced to allow parties to change their stand in a trial de novo, they are permitted to stand by their original defense. By filing the manifestation within the reglementary period, the petitioners effectively redefined their stand as required by the rules. Consequently, the respondent Judge's decision to disregard the manifestation and declare the petitioners in default was an error in the application of procedural law.
Main Doctrine
A defendant in an appealed case from a justice of the peace court to the Court of First Instance may reproduce his answer filed in the inferior court by a proper manifestation within the reglementary period, and this constitutes substantial compliance with the rules, thus preventing a declaration of default.