Title
Adan vs. Pantalla
Case
G.R. No. L-12399
Decision Date
May 29, 1959
Plaintiff sued defendants over land ownership; trial court denied defendants' continuance and new trial motions, ruling for plaintiff. Appeals upheld decision, citing defendants' negligence and declining to review damages.
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Case Digest (G.R. No. L-12399)

Facts:

Background of the Case

  • Plaintiff Nicasia Pantalla filed an action in the Court of First Instance of Camarines Sur against defendants Rufino Adan, Celedonio Ribares, Elena Vda. de Clave, and Fabian Samson to recover ownership and possession of a parcel of land.
  • Defendants claimed that portions of the land belonged to them, though the exact areas were undetermined.

Trial Proceedings

  • The case was set for hearing on March 11, 1955. Defendants' counsel received notice of the hearing on February 17, 1955.
  • On the trial date, both parties' counsel informed the court they were ready for trial. Plaintiff presented her evidence, including testimony and documents.
  • After plaintiff rested her case, defendants' counsel moved for a continuance, claiming his clients had not arrived despite being notified. Plaintiff opposed, arguing that defendants' counsel had ample notice and had informed the court of readiness.
  • The court denied the motion for continuance and rendered judgment in favor of the plaintiff, declaring her the owner of the land and ordering defendants to pay damages, restore possession, and deliver 100 cavans of palay annually until full restoration.

Motion for New Trial

  • On April 14, 1955, defendants filed a motion for a new trial, alleging that some defendants received notice late or were unable to attend due to illness or travel.
  • The motion was unverified and lacked affidavits of merit. Plaintiff opposed the motion.
  • Defendants' counsel later submitted a supplementary memorandum with affidavits of merit, but the court found the motion unfounded and denied it.

Appeal to the Court of Appeals

  • Defendants appealed to the Court of Appeals, which affirmed the trial court's decision.
  • Defendants then filed a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Denial of Motions for Continuance and New Trial:

    • Motions for continuance are addressed to the sound discretion of the court. The trial court did not abuse its discretion in denying the motion, as defendants' counsel had ample notice (over 20 days) to prepare for trial and notify his clients.
    • Defendants' failure to appear was due to their own negligence, as they were obligated to inform their counsel of their whereabouts to ensure timely communication.
    • The reasons provided for the motion for new trial (late notice and inability to attend) were not justifiable, as the defendants had sufficient time to prepare and appear.
  2. Excessive Damages:

    • The Supreme Court declined to review the damages awarded, as it involved a factual determination. Questions of fact are not within the Court's jurisdiction in a petition for review.

Conclusion:

  • The Supreme Court found no error in the lower courts' decisions and affirmed the judgment in favor of the plaintiff. The defendants' motions were properly denied, and the damages awarded were not subject to review.


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