Mercado Guinea v. Ramonal
REITERATIONFacts
The Antecedents: This case concerns a dispute over Lot No. 2059 of the Cagayan de Oro cadastre, an area of 43,690 square meters. The petitioners, claiming to be in possession of the lot since their birth, alleged that their possession was only interrupted during the war until February 1966, when they reacquired legal possession. The respondent, Matilde S. Vda. de Ramonal, is also involved in the litigation concerning this property. Procedural History: The petitioners initiated Civil Case No. 2766 in the Court of First Instance of Misamis Oriental. During the trial, the respondent Judge Bernardo Teves issued several orders that the petitioners sought to annul. Specifically, an order on June 28, 1973, sustained an objection to the testimony of an eighth witness, Isabelo Ello, and implied that Mrs. Ramonal possessed the lot during the period in question, stating that paragraph 9 of the complaint, which admitted non-possession from 1940 to February 1966, could not be amended. A motion for reconsideration of this order was denied on January 14, 1974. Further hearings on February 22, 1974, saw the respondent Judge terminate the presentation of the petitioners' evidence after their counsel's repeated absences, despite the counsel's explanations and motions for reconsideration. The Petition: The petitioners filed this special civil action for certiorari to annul the aforementioned orders, alleging grave abuse of discretion amounting to lack or excess of jurisdiction. They argued that the respondent Judge erred in disallowing the testimony of their eighth witness, Isabelo Ello, and in curtailing the presentation of their evidence without their consent due to their counsel's tardiness. The petition was filed on May 21, 1974, after the events of February 22, 1974, and was given due course due to the Court's initial impression of potential injustice.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion in disallowing the testimony of Isabelo Ello. Whether the respondent Judge committed grave abuse of discretion in terminating the presentation of petitioners' evidence.
Ruling
The Supreme Court dismissed the petition, holding that the respondent Judge did not commit grave abuse of discretion in disallowing the testimony of Isabelo Ello and in terminating the presentation of petitioners' evidence. The Court found no injustice committed and affirmed the orders of the respondent Judge.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the respondent Judge did not abuse his discretion in disallowing the testimony of Isabelo Ello. The Court reasoned that Ello's testimony, if it were to prove possession from 1940 to 1966 (except during wartime), would be merely cumulative, as seven witnesses had already testified to the same effect. The Court cited Section 6 of Rule 133 of the Rules of Court, which allows a court to stop further testimony on a point when the evidence is already sufficiently full. Furthermore, the Court noted that Ello's testimony would be at variance with the admission in paragraph 9 of the complaint, which stated that the plaintiffs were not in possession of the lot from 1940 to February 1966. If Ello were to testify that possession was uninterrupted, it would directly nullify this admission, a consequence considered by the respondent Judge. On Issue 2: The Supreme Court found that the petitioners displayed a lack of candor regarding the events of February 22, 1974, which led to the termination of their evidence presentation. The Court noted the petitioners' counsel's tardiness and the subsequent dilatory tactics employed. The Court concluded that the termination of the presentation of evidence was justified under the circumstances, especially given the prior issues with the pleadings and the cumulative nature of the evidence sought to be presented. The petition was dismissed due to these deficiencies and suppressions of facts, indicating it was bereft of merit.
Main Doctrine
The Supreme Court affirmed that a trial court did not commit grave abuse of discretion in disallowing testimony that would be merely cumulative to evidence already presented, citing Section 6 of Rule 133 of the Rules of Court. Additionally, the Court reiterated that admissions made in verified pleadings, even in amended complaints, are binding and cannot be contradicted by subsequent testimony that directly nullifies such admissions.