Say v. Dizon
REITERATIONFacts
The Antecedents: Respondent Gabriel Dizon filed a complaint for Declaration of Nullity of the Deed of Absolute Sale against Robert Dizon and petitioners Helen, Gilda, Henry, and Danny Say. The RTC dismissed the complaint due to forum shopping. After the dismissal attained finality, petitioners filed an Ex-Parte Motion for Leave of Court to Set Defendants' Counterclaim for Hearing. A Notice of Hearing was issued for March 13, 2014. Petitioners filed their Judicial Affidavits on March 12, 2014, one day before the scheduled hearing. Procedural History: Respondent opposed the admission of the Judicial Affidavits, claiming they were filed out of time under Section 2(a) of the Judicial Affidavit Rule (JAR), which requires filing not later than five days before the scheduled hearing. Petitioners argued that the March 13, 2014 hearing was for their ex-parte motion and not yet for the counterclaim itself, thus the five-day period had not commenced. The RTC, in an Order dated September 2, 2014, admitted the Judicial Affidavits, citing that technicalities must give way to substantial justice and that Section 10(a) of the JAR allows late submission. The RTC denied reconsideration in an Order dated April 1, 2015, reiterating the substantial justice principle and imposing a P2,500.00 fine for the late submission. The Court of Appeals (CA) set aside the RTC Orders, finding grave abuse of discretion for admitting the affidavits without proof of compliance with the conditions under Section 10(a) of the JAR (valid reason, no undue prejudice, and payment of fine), noting that only the fine was paid. The Petition: Petitioners filed a petition for review on certiorari assailing the CA's decision and resolution, arguing that the CA erred in finding grave abuse of discretion on the part of the RTC.
Issue(s)
Whether the Court of Appeals erred in finding grave abuse of discretion on the part of the Regional Trial Court when it admitted petitioners' Judicial Affidavits that were belatedly filed. Whether the conditions under Section 10(a) of the Judicial Affidavit Rule were sufficiently met for the belated submission of the Judicial Affidavits.
Ruling
The petition is meritorious. The Decision and Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Orders of the Regional Trial Court are REINSTATED.
Ratio Decidendi
On the Issue of Grave Abuse of Discretion: The Court found that the RTC did not act with grave abuse of discretion amounting to excess or lack of jurisdiction, and the CA erred in reversing the RTC's Orders. On the Issue of Belated Submission of Judicial Affidavits and Compliance with Section 10(a) of the JAR: The Judicial Affidavit Rule (JAR) mandates the filing of judicial affidavits not later than five days before the scheduled hearing. However, Section 10(a) of the JAR provides a caveat, allowing for the late submission of judicial affidavits once, provided that the delay is for a valid reason, would not unduly prejudice the opposing party, and the defaulting party pays a fine. In this case, petitioners complied with the fine. Their reason for the delay, stemming from a good-faith misinterpretation of the Notice of Hearing as a mere notification rather than a formal order granting their ex-parte motion, was considered an honest procedural mistake, not a deliberate intent to flout the rules. The affidavits were submitted only one day before the hearing, demonstrating no wanton or deliberate act to delay proceedings. The Court emphasized that striking out the affidavits and depriving petitioners of their opportunity to pursue their counterclaim would be too harsh a penalty and would deny them due process over a minor technicality. The admission of the affidavits did not unduly prejudice the respondent, as no evidence was presented on the scheduled hearing date, and respondent was given the chance to present rebuttal evidence later, negating any supposed prejudice. The Court reiterated that when no substantial rights are affected and the intention to delay is not manifest, it is sound judicial discretion to allow belated submissions to ventilate the merits of the case fully. The RTC exercised its discretion in relaxing the rigid application of the JAR in the interest of substantial justice, which is a prerogative of courts to ensure a speedy resolution of cases while respecting parties' right to due process. Therefore, the CA's finding of grave abuse of discretion was unwarranted.
Main Doctrine
The Court reiterated that while the Judicial Affidavit Rule (JAR) mandates timely submission of judicial affidavits, Section 10(a) allows for belated submission under specific conditions: a valid reason for delay, no undue prejudice to the opposing party, and payment of a fine. Grave abuse of discretion is committed when a lower court admits belatedly filed judicial affidavits without requiring compliance with these conditions, or conversely, when it strictly enforces technicalities to the prejudice of substantial justice and due process.