Corpus v. Corpus
REITERATIONFacts
The Antecedents: Plaintiffs Leona Corpus and Iladia Corpus, claiming to be the legal heirs of Domingo Corpus and Clara Sibayan, filed an action for recovery of possession of a parcel of land against defendants Jacinta Corpus and Pedro Aduca. The land was registered under TCT No. 49663 in the name of "Heirs of Domingo Corpus." Plaintiffs alleged that Domingo Corpus and Clara Sibayan were their predecessors-in-interest, and that Jacinta Corpus, an illegitimate child of Domingo Corpus with Fermina Tabas, had no right to inherit. Defendants claimed they purchased the property from Doroteo Cresencia via a "Deed of Reconveyance and Confirmation," asserting they were also heirs of Domingo Corpus and intended vendees. Procedural History: The trial court set a pre-trial conference. Defendants' counsel filed a motion for postponement, citing a conflict with another hearing. Plaintiffs opposed the motion, arguing lack of proper notice. The trial court denied the motion for postponement, finding it non-compliant with the Rules of Court, and allowed plaintiffs to present evidence ex-parte. Defendants received the order denying postponement but took no action to reconsider it. The trial court rendered a decision in favor of the plaintiffs, declaring them legal heirs and owners, ordering defendants to vacate and deliver possession and title, and awarding damages and attorney's fees. The Petition: Defendants filed a motion for new trial, alleging mistake or excusable negligence for their non-appearance at pre-trial and claiming Domingo Corpus died in 1956, not 1948, which would entitle Jacinta Corpus to a share. The trial court denied the motion for new trial, stating the order denying postponement had become final and the alleged misrepresentation of Domingo Corpus's death date was not a ground for new trial. Defendants appealed, assigning as errors the denial of their motion for postponement and the denial of their motion for new trial.
Issue(s)
Whether the trial court erred in denying the defendants' motion for postponement of the pre-trial conference. Whether the trial court erred in denying the defendants' motion for new trial.
Ruling
The Supreme Court affirmed the decision of the trial court. The appeal was found to be without merit.
Ratio Decidendi
On the denial of the motion for postponement: The Court found no abuse or irregularity in the denial. The motion for postponement did not show proof of service to the adverse party as required by the Rules of Court. The defendants' counsel merely stated "Copy furnished" without indicating the manner of service, and later claimed it was sent by registered mail without providing an affidavit of mailing or the registry receipt. Furthermore, the motion did not state the time and place for its hearing, rendering it a "useless piece of paper" as per established jurisprudence. The Court emphasized that the grant or denial of a motion for postponement is discretionary, and parties cannot presume it will be granted. The defendants' counsel's appearance in another court did not excuse the defendants' own failure to appear, as they could have attended themselves. The defendants also failed to inquire about the action taken on their motion. On the denial of the motion for new trial: The Court found no error in the denial. The order denying the motion for postponement, which was received by the defendants on September 12, 1967, had become final when the motion for new trial was filed on July 1, 1968. The Court reiterated that the alleged misrepresentation of Domingo Corpus's death date was not a valid ground for a new trial, especially since the defendants' theory of ownership was based on a "Deed of Reconveyance and Confirmation" and not directly on successional rights. The Court also noted that reopening the case for the defendants' evidence would likely not change the outcome and could constitute a change in the theory of the defense, which is generally not allowed. The nature of the "Deed of Reconveyance and Confirmation" was also examined, with the Court finding that Pedro Aduca acted merely as a representative of the heirs of Domingo Corpus, not as a vendee in his own right.
Main Doctrine
A motion for postponement that fails to comply with the Rules of Court regarding notice to the adverse party and setting of a hearing date is a useless piece of paper and may be denied. The grant or denial of a motion for postponement is discretionary, and parties cannot presume it will be granted. Failure to appear at a pre-trial conference after a motion for postponement was denied, without further action to set aside the denial, can lead to presentation of evidence ex-parte and a decision rendered against the non-appearing party.