Gonzales v. Bugaay
REITERATIONFacts
The Antecedents: This case concerns the estate of the deceased spouses Bartolome Ayad and Marcelina Tejada, who had five children: Enrico, Encarnacion, Consolacion, Maximiano, and Mariano. Mariano and Maximiano predeceased their parents without issue. Enrico remained single. Encarnacion is survived by her children, the petitioners, including Nenita Gonzales. Consolacion was married to the late Imigdio Bugaay and is survived by her children, the respondents, including Mariano Bugaay. The petitioners, represented by Nenita Gonzales, filed an Amended Complaint for Partition and Annulment of Documents with Damages, alleging that Enrico executed fraudulent documents in 1987 transferring all of the Spouses Ayad's properties to Consolacion and the respondents, thereby disregarding the petitioners' rights. They sought partition of the estate, nullification of the documents, and damages. Procedural History: The Regional Trial Court (RTC) of Lingayen, Pangasinan, Branch 39, initially rendered a Decision on November 24, 1995, awarding a one-fourth share of the estate to Enrico, Maximiano, Encarnacion, and Consolacion, and declaring the Deed of Extrajudicial Settlement and Partition executed by Enrico and respondents, along with other titles, as null and void. Respondents filed a motion for reconsideration/new trial. After a period of inactivity and a subsequent writ of execution, the RTC, in an Order dated August 29, 2003, granted the respondents' motion for reconsideration/new trial for the specific purpose of admitting documents. However, instead of presenting these documents, respondents filed a demurrer to evidence. The RTC denied this demurrer in its Orders dated April 13, 2005, and August 8, 2005. The respondents then filed a petition for certiorari with the Court of Appeals (CA), which reversed the RTC's orders and dismissed the petitioners' complaint. The Petition: The petitioners, represented by Nenita Gonzales, filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Decision of the Court of Appeals dated March 23, 2006, and its Resolution dated June 2, 2006. They argue that the CA erred in dismissing their Amended Complaint. The core of their argument is that the respondents' demurrer to evidence was improperly filed and granted, as it was filed after the RTC had already rendered its Decision and after the CA had granted a motion for reconsideration for the specific purpose of admitting documents, which respondents failed to do. Petitioners contend that the CA's dismissal of their complaint was contrary to law, rules of procedure, and jurisprudence, and that the RTC's original Decision should stand.
Issue(s)
Whether the Court of Appeals erred in dismissing the Amended Complaint, considering the impropriety of the respondents' demurrer to evidence. Whether the original Decision of the Regional Trial Court should be reinstated, given the improper filing and granting of the demurrer to evidence.
Ruling
The petition is GRANTED. The assailed Decision and Resolution of the Court of Appeals are SET ASIDE, and the Orders of the Regional Trial Court denying respondents' demurrer are REINSTATED. The Decision of the Regional Trial Court dated November 24, 1995 STANDS.
Ratio Decidendi
On the propriety of the demurrer to evidence and the CA's error: The Court reiterated that a demurrer to evidence is a motion to dismiss on the ground of insufficiency of evidence, which must be filed after the plaintiff has completed the presentation of his evidence but before the court renders its judgment. The Court emphasized that being considered a motion to dismiss, a demurrer to evidence must clearly be filed before the court renders its judgment. In this case, the respondents filed their demurrer to evidence after the RTC had already promulgated its Decision. While the RTC had granted respondents' motion for reconsideration and/or new trial, it was for the specific purpose of receiving and offering for admission certain documents. However, instead of presenting these documents, the respondents filed a demurrer to evidence. The Court found that this action rendered their motion for reconsideration moot and that the RTC's original Decision should have stood. Therefore, the CA committed reversible error in granting the demurrer and dismissing the amended complaint for insufficiency of evidence, as the demurrer was no longer an available remedy. The RTC had correctly denied it. On the reinstatement of the RTC's original Decision: The Court held that since the demurrer to evidence was improperly filed and granted by the CA, the original Decision of the RTC dated November 24, 1995, which declared certain documents null and void and ordered the partition of the estate, should be reinstated. The CA's reversal of the RTC's denial of the demurrer was deemed an error in law and procedure.
Main Doctrine
A demurrer to evidence must be filed before the court renders its judgment. If filed after a decision has been promulgated, it is no longer a proper remedy and should not be granted.