Sablas v. Sablas
REITERATIONFacts
The Antecedents: Respondents filed a complaint for judicial partition, inventory, and accounting against petitioner spouses. Petitioners were served summons and filed a motion for extension to file their answer. They filed their answer out of time. Procedural History: The trial court admitted the answer despite being filed out of time, observing that no motion to declare petitioners in default was filed. Respondents filed a motion to declare petitioners in default, which was denied. Respondents challenged this denial via certiorari in the Court of Appeals, alleging grave abuse of discretion by the trial court. The Petition: The Court of Appeals ruled that the trial court committed grave abuse of discretion by admitting the answer, holding that it had no recourse but to declare petitioners in default. Petitioners now assail this decision, arguing the Court of Appeals misconstrued Section 3, Rule 9 of the Rules of Court.
Issue(s)
Whether the Court of Appeals erred in ruling that the trial court committed grave abuse of discretion in admitting the answer filed out of time. Whether the trial court correctly denied the motion to declare petitioner spouses in default.
Ruling
The petition is GRANTED. The July 17, 2000 decision of the Court of Appeals is REVERSED and SET ASIDE, and the December 6, 1999 order of the Regional Trial Court is REINSTATED. The case is REMANDED to the trial court for further proceedings.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in ruling that the trial court committed grave abuse of discretion in admitting the answer filed out of time: The Supreme Court agreed with the petitioner spouses, holding that the Court of Appeals erred in its ruling. The Court emphasized that a declaration of default requires specific procedural steps, namely, a motion filed by the claiming party and notice to the defending party. The Court clarified that Section 3, Rule 9 of the Rules of Court mandates that the court shall declare a defending party in default "upon motion of the claiming party with notice to the defending party." This means the trial court cannot declare a party in default motu proprio. In this case, no motion to declare the petitioner spouses in default was filed by the respondents before the answer was admitted. Therefore, the trial court did not commit grave abuse of discretion in admitting the answer, even if it was filed out of time, as the procedural prerequisite for default had not been met. The policy of the law favors the trial of cases on their merits, and judgments by default are generally frowned upon. On the issue of whether the trial court correctly denied the motion to declare petitioner spouses in default: The Supreme Court affirmed the trial court's denial of the motion to declare the petitioner spouses in default. The Court reiterated that a declaration of default can only be made upon motion of the claiming party. Since the answer was already filed and admitted by the trial court before any motion to declare the defendants in default was filed, it was erroneous for the Court of Appeals to insist on a declaration of default. The Court cited jurisprudence, such as Cathay Pacific Airways, Ltd. v. Hon. Romillo, Jr. and Indiana Aerospace University v. Commission on Higher Education, which held that it is error to declare a party in default after an answer has been filed. The Court stressed that the policy of the law is to have cases tried on the merits, allowing all parties to present their claims and evidence, thereby subserving due process and enabling accurate factual findings and legal conclusions.
Main Doctrine
A declaration of default requires a motion from the claiming party and notice to the defending party. The trial court cannot motu proprio declare a defendant in default. An answer filed before a declaration of default, even if out of time, should be admitted if no prejudice is caused to the plaintiff and there is no intent to delay the case.