Jimenez v. Jimenez
REITERATIONFacts
The Antecedents: Plaintiffs, minor children represented by their mother, alleged that their father, defendant Arturo T. Jimenez, won P400,000.00 in a sweepstakes draw and deposited P5,000.00 each (total P30,000.00) in their names with Equitable Banking Corporation as a gift and for their future security. He allegedly gave the passbooks to their mother. The bank refused to allow withdrawals when the mother attempted to do so, stating the deposits had been withdrawn by Arturo T. Jimenez without the plaintiffs' knowledge and contrary to the passbook requirement. Procedural History: The Court of First Instance of Manila initially ordered a pre-trial conference. The parties agreed that the sole issue was whether defendant Jimenez was justified in withdrawing the deposits. Subsequently, the court issued an order for the parties to submit memoranda, stating the issue was whether Arturo Jimenez withdrew illegally the money by executing an affidavit that the passbook was lost. The court rendered a decision without trial, condemning defendant Jimenez to restore the deposits, pay moral damages, attorney's fees, and costs. Defendant Equitable Banking Corporation was absolved. The Petition: Defendant Jimenez appealed, assailing the validity of the judgment for having been rendered without trial and without evidence to support the court's findings of fact.
Issue(s)
Whether the judgment was validly rendered without trial and evidence. Whether the defendant was justified in withdrawing the deposits. Whether efforts toward compromise were made as required by Article 222 of the Civil Code.
Ruling
The appealed judgment is set aside and the case is ordered remanded to the court of origin for further proceedings. No costs.
Ratio Decidendi
On the validity of the judgment rendered without trial and evidence: The Supreme Court held that the judgment was invalid because it was rendered without trial and without evidence to support its findings of fact. There were many controverted matters, such as the ownership of the deposits, whether they were donations or given in trust, the bank's rules and regulations, banking practices, and the fact of moral damages and attorney's fees, which required proof. The parties did not stipulate on any controverted allegation of fact. While they defined the issue at pre-trial, this issue could not be resolved without findings of fact based on evidence or admissions in the pleadings. The submission of memoranda did not make the case ripe for decision as questions of fact remained to be determined. On whether the defendant was justified in withdrawing the deposits: This issue could not be resolved as it was intrinsically linked to the controverted facts that were not proven due to the lack of trial and reception of evidence. The ownership of the deposits, the nature of the transaction (donation vs. safekeeping), and the circumstances surrounding the withdrawals were all matters requiring evidentiary determination. Without evidence, the court could not validly conclude whether the defendant's actions were justified or not. On the requirement of efforts toward compromise (Article 222, Civil Code): The Court noted that Article 222 of the Civil Code forbids suits between members of the same family unless efforts toward compromise have been made and failed. Such efforts must be properly proved, or the case will have to be dismissed. Since no evidence of such efforts was presented, this further necessitated the remand of the case for proper proceedings, including the determination of compliance with this mandatory provision.
Main Doctrine
A judgment rendered without trial and without evidence to support its findings of fact, particularly on controverted matters, is invalid and must be set aside and the case remanded for further proceedings.