Estabaya v. Mijares
REITERATIONFacts
The Antecedents: Petitioner Antonio Estabaya was the defendant in an ejectment case filed by Rosita L. Garcia. During the hearing for the reception of petitioner's evidence, his counsel requested a deferment due to illness and confinement, submitting a Certificate of Confinement. The Court denied the postponement, deeming the certificate unsworn, and considered the case submitted for decision. Procedural History: Petitioner moved to lift the order, explaining the certificate was unsworn due to the physician's limited availability and submitted a notarized certificate. The respondent Court denied this motion for lack of merit. Petitioner filed another motion for reconsideration and/or to set aside the order considering the case submitted, attaching a notarized medical certificate. This motion was also denied. The Petition: Petitioner filed a Petition for Certiorari seeking to set aside the respondent Court's Orders dated September 30, 1980, and December 3, 1980, alleging grave abuse of discretion.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion in denying the petitioner's motion for postponement and considering the case submitted for decision despite the counsel's documented hospitalization.
Ruling
The petition is granted. The respondent Court is ordered to continue hearing Civil Case No. 045438 until its termination, with no petitions for postponement to be entertained provided ample notice of hearing is given, and to render judgment accordingly.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the respondent Judge committed grave abuse of discretion because the petitioner presented a valid and substantiated ground for his request for deferment. The Court found that the sworn certificate of confinement, the hospital deposit slip, and the notarized medical certificate sufficiently proved that the counsel was hospitalized on the date of the hearing, justifying his non-attendance. The Court emphasized that while speed in judicial administration is desirable, it must yield to the higher cause of justice. Applying the precedent in Rexwell Corporation vs. Canlas, the Court noted that postponement and continuance are essential parts of the procedural system, provided that no substantial rights are affected and the intention to delay is not manifest. In this instance, the private respondent did not refute the fact of the counsel's confinement, and the petitioner's effort to provide a notarized certificate shortly after the hearing showed good faith. Therefore, the respondent Judge's refusal to grant a brief continuance was an arbitrary act that favored technicality over the fundamental right to a fair hearing.
Main Doctrine
A court commits grave abuse of discretion in denying a request for postponement when there is a valid ground, such as the illness and confinement of counsel, as speed in judicial administration must yield to the cause of justice.