Nazareth v. Santos
REITERATIONFacts
The Antecedents: Private respondent Renato Santos filed an Amended Complaint against petitioners Rufino Nazareth, Domingo Nazareth, Romana Aniana Vda. de Ferrera, and Cesar Ferrera for accounting before the Court of Agrarian Relations (CAR), Branch I, Pasig, Metro Manila (Civil Case No. 1304). Procedural History: Pursuant to Presidential Decree No. 946, parties were required to submit affidavits as direct testimonies. A hearing was held on May 28, 1978, where the plaintiff adopted his sworn statement. The hearing was postponed to July 28, 1978, by agreement. On July 28, 1978, petitioners-defendants, except Romana Aniana Vda. de Ferrera, appeared with a motion for postponement, citing counsel's appointment as de officio counsel for a detention prisoner and as a witness in another case. The trial court denied the motion, granted the plaintiff's motions to terminate cross-examination and waive the right to cross-examine defendants, admitted the plaintiff's exhibits, and admitted the defendants' affidavit as direct testimony. The case was then considered submitted for decision. Petitioners' motion for reconsideration was denied. The Court of Appeals affirmed both orders. The Petition: Petitioners sought review of the Court of Appeals' decision, alleging grave abuse of discretion by the trial court in denying the motion for postponement, denying the opportunity to adduce evidence, and considering the case submitted for decision without authority.
Issue(s)
Whether the respondent Appellate Court committed reversible error in affirming the Order of the Court of Agrarian Relations which denied petitioners-defendants' Motion for postponement and resetting of the hearing and considered the case submitted for decision. Whether the trial court committed a grave abuse of discretion in denying the motion for postponement filed by petitioners. Whether the trial court committed a grave abuse of discretion in denying the motion of the petitioners that they be allowed to adduce evidence in support of their defense. Whether the trial court has the authority to consider the case submitted for decision.
Ruling
The petition is denied, and the case is remanded to the proper Regional Trial Court for resolution on the merits.
Ratio Decidendi
On the denial of the motion for postponement: The Court held that Presidential Decree No. 946, Section 17, explicitly states that the absence of counsel is not a ground for postponement or continuance in agrarian cases, provided they were duly notified. The counsel was duly notified and had agreed to the resetting, implying no prior conflicting commitments. The plea for postponement was made on the day of the hearing, and the Court found that dilatory tactics were resorted to by the petitioners, who had previously failed to appear at several hearings. The trial court had been liberal in granting previous postponements and had warned that the hearing would proceed if they failed to appear. Therefore, the denial of the postponement was justified, as a plaintiff is entitled to speedy justice. On the denial of the motion for postponement: The Court held that Presidential Decree No. 946, Section 17, explicitly states that the absence of counsel is not a ground for postponement or continuance in agrarian cases, provided they were duly notified. The counsel was duly notified and had agreed to the resetting, implying no prior conflicting commitments. The plea for postponement was made on the day of the hearing, and the Court found that dilatory tactics were resorted to by the petitioners, who had previously failed to appear at several hearings. The trial court had been liberal in granting previous postponements and had warned that the hearing would proceed if they failed to appear. Therefore, the denial of the postponement was justified, as a plaintiff is entitled to speedy justice. On the denial of the motion to adduce evidence: Since the denial of the postponement was proper, the subsequent denial of the petitioners' motion to adduce evidence in support of their defense was also justified. The petitioners failed to provide any indication of the meritoriousness of their defense before either the trial court or the appellate court. Given that the case was for accounting, which primarily involves documentary evidence, some preliminary showing of their case could have influenced the outcome. On the authority to consider the case submitted for decision: The Court found it erroneous to allege that the trial court lacked authority to consider the case submitted for decision in the absence of specific authorization in the Agrarian Law. Such a recourse is within the inherent power of the court. Furthermore, Section 17, paragraph 2 of P.D. 946 explicitly enjoins that no order of the Courts of Agrarian Relations on any issue shall be contested before the appellate courts until the hearing has been terminated and the case decided on the merits. The counsel for the petitioners had disregarded this injunction, unduly delaying the resolution of the case.
Main Doctrine
The absence of counsel in agrarian cases is not a ground for postponement or continuance, especially when the plea is made on the very day of the hearing and dilatory tactics are evident, as the court is justified in considering the case submitted for decision on the plaintiff's evidence.