Carandang v. Republic of the Philippines
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an expropriation case initiated by the Republic of the Philippines (National Irrigation Administration) against Anselmo Carandang, Benjamin Carandang, Armando Carandang, and Esterlita Carandang. The petitioners, who were the defendants in the expropriation case, allege that they were denied their day in court, thereby violating their constitutional right to procedural due process. 2. Procedural History: The petitioners appeared before the respondent Judge on June 7, 1978, at 1:30 PM, only to be informed that the matter had already been heard at 9:00 AM that same morning. Consequently, an order of default was issued by Judge Fidel P. Purisima, declaring the defendants in default and authorizing the plaintiff to present evidence ex parte. A subsequent motion to lift this order of default was filed by the petitioners but was subsequently denied. 3. The Petition: The petitioners filed a certiorari and prohibition proceeding before the Supreme Court, arguing that the denial of their motion to lift the order of default and the subsequent issuance of the default order constituted a violation of their right to procedural due process. They contend that they were not given a proper opportunity to be heard. The Republic of the Philippines, through the Solicitor General, commented on the petition, emphasizing the doctrine that certiorari requires a showing of lack of or excess of jurisdiction or grave abuse of discretion. However, the Supreme Court, considering the importance of a hearing and the potential for a colorable claim of grievance, remanded the case to the lower court to allow the petitioners to be heard at a pre-trial.
Issue(s)
Whether the petitioners were denied their constitutional right to procedural due process. Whether the order of default issued by the respondent Judge constituted a grave abuse of discretion.
Ruling
The Supreme Court remanded the case to the lower court to enable the petitioners to be heard at the pre-trial on a date to be duly set by the respondent Judge. No costs were awarded.
Ratio Decidendi
On Whether the petitioners were denied their constitutional right to procedural due process: The Court found that the petitioners' claim of denial of procedural due process was plausible. They asserted that they were informed of the hearing at 9:00 AM on June 7, 1978, but they appeared at 1:30 PM, only to be informed that the hearing had already concluded. This led to an order of default being issued against them. The Court acknowledged that while the petitioners could not directly impute blame on the respondent Judge, they could seek protection under the due process clause based on a plea of excusable neglect. The essence of a hearing, which is of paramount importance, was allegedly denied to them. The Court emphasized that in expropriation cases, which involve the exercise of the State's power of eminent domain, adherence to the requirements of procedural due process is even more critical. The Court cited Visayan Refining Co. v. Camus to underscore that expropriation is fundamentally a constitutional question of due process. On Whether the order of default issued by the respondent Judge constituted a grave abuse of discretion: The Court acknowledged the well-settled doctrine that for certiorari to lie, there must be a lack of or excess of jurisdiction or a grave abuse of discretion amounting to jurisdictional infirmity. The Solicitor General argued that on the given facts, a grave abuse of discretion could not be concluded. However, the Court, considering its receptiveness to pleas where a hearing is of the essence, found that the cause of justice would be better served by lifting the default order. This would allow the petitioners to present their evidence and have their day in court. The Court noted that the order for pre-trial was written to indicate 9:30 AM, but the petitioners were under the impression it was at 1:30 PM. This discrepancy, while not directly attributable to the judge, was considered a basis for granting relief to prevent a miscarriage of justice, especially given the nature of expropriation proceedings.
Main Doctrine
While a grave abuse of discretion amounting to jurisdictional infirmity is generally required for certiorari to lie, the Supreme Court may lift a default order to enable a party to present evidence, especially in expropriation cases, to better serve the cause of justice and uphold the constitutional right to procedural due process, even in instances of excusable neglect.