Chingan v. La Guardia
REITERATIONFacts
The Antecedents: Respondent Gabriel La Guardia, a tenant, filed a petition against petitioner Cristina Chingan, a landholder, for a reliquidation of past harvests. Chingan admitted La Guardia's status as a tenant and the contributions to production but claimed ownership of only one-half of the land. Procedural History: The case was set for hearings on December 13, 1961, and January 17, 1962. Chingan and her counsel failed to appear on both dates. The Court of Agrarian Relations allowed La Guardia to present evidence ex-parte and submitted the case for decision. Upon Chingan's motion, the case was reopened in the interest of justice. After several postponements, the case was again set for hearing on June 8, 1962. Chingan again failed to appear, and the court allowed La Guardia to present evidence ex-parte for the second time. A decision was rendered on September 7, 1962. Chingan filed a motion for reconsideration on October 18, 1962, alleging she received the notice for the June 8 hearing only on June 14, 1962. This motion was denied for lack of an accompanying affidavit of merit. The Petition: Petitioner Chingan filed a petition for review on certiorari, arguing that the respondent Judge erred in refusing to reopen the case despite her claim of lack of timely notice for the June 8, 1962 hearing. She also asserted that the judge erred in not considering her defense of owning only one-half of the land.
Issue(s)
Whether the respondent Judge erred in refusing to reopen the case despite petitioner's claim of receiving the notice of hearing late. Whether the respondent Judge erred in not considering petitioner's special defense of ownership of only one-half of the land.
Ruling
The petition is denied. The decision of the Court of Agrarian Relations is affirmed.
Ratio Decidendi
On the issue of refusing to reopen the case: The Court held that the petitioner's claim was unmeritorious. Petitioner had previously failed to appear on two prior occasions, and the case was reopened once to give her an opportunity to be heard. Her failure to appear on June 8, 1962, even if she received the notice late, demonstrated inexcusable negligence, especially since she took no steps to inquire about the case after the decision was rendered. Furthermore, her motion for reconsideration was fatally defective for failing to comply with Section 2 of Rule 37 of the Rules of Court, which requires an affidavit of merit to be attached to such motions. The absence of this affidavit made the denial of her motion proper. On the issue of not considering the special defense of ownership: The Court found this assertion devoid of merit. While the petitioner alleged in her answer that she owned only one-half of the land, she failed to substantiate this claim with any evidence. On the contrary, the evidence on record clearly established the tenancy relationship between respondent La Guardia and petitioner Chingan, and that Chingan alone had been sharing the produce with La Guardia from the inception of their relationship up to the filing of the case. Therefore, her defense was not proven and could not be considered.
Main Doctrine
The Supreme Court reiterated that a motion for reconsideration or reopening of a case, particularly when alleging lack of timely notice, must be accompanied by an affidavit of merit as required by Section 2 of Rule 37 of the Rules of Court. Failure to comply with this mandatory requirement is fatal to the motion. Furthermore, the Court emphasized that repeated failures to appear at scheduled hearings, without a valid and excusable justification, constitute inexcusable negligence that prevents a party from obtaining relief, especially when the case has already been previously reopened to give the party an opportunity to be heard.