Facts:

The case revolves around Maria Adela, who filed a petition against the Judge of the Court of First Instance of Ilocos Sur. The proceedings stemmed from a default judgment rendered against Celestino Mina in an action initiated by Jose Bona for the recovery of 5,825.75 pesos. The summon was served to Mina on November 24, 1902. At that time, Mina presented a written statement and a doctor’s certificate indicating that he was unable to travel due to a lung disease. Subsequently, on February 25, 1903, the plaintiff amended the complaint to reduce the claimed amount to 5,725.75 pesos, and a new summons was served to Mina on March 9, 1903. Mina reiterated his medical condition through a similar written statement and doctor’s certificate. Despite the service of process, Mina failed to appear before the court, leading to a default judgment entered against him on August 15, 1903. Mina passed away on November 7, 19

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Facts:

Initiation of the Original Action

• Jose Bona commenced a case in the Court of First Instance of Ilocos Sur against Celestino Mina to recover the sum of 5,825.75 pesos.
• The summons in the original action was served on November 24, 1902.

Defendant's Initial Response

• Upon service, Celestino Mina provided a written statement to the municipal president, indicating that due to sickness he could not appear in court.
• Mina also submitted a doctor's certificate confirming he was suffering from a lung disease that rendered him incapable of traveling by vehicle or on horseback.

Amendment of the Complaint and Reissuance of Summons

• On February 25, 1903, the plaintiff amended his complaint, reducing the claim to 5,725.75 pesos.
• A new summons was issued and served on March 9, 1903.

Defendant's Subsequent Conduct

• On receiving the new summons, the defendant again provided a written statement similar to his earlier submission, accompanied by another doctor's certificate confirming his inability to travel.
• These documents were forwarded to the clerk’s office and incorporated into the case expediente.
• Despite his submissions, Mina failed to appear before the court on any occasion.

Entry of Default Judgment

• On August 15, 1903, the Court of First Instance rendered a final judgment by default against Celestino Mina for the recovery of 5,725.75 pesos, including costs.
• Shortly thereafter, on November 7, 1903, Celestino Mina died.

Petition for Relief

• The widow of the late Celestino Mina, claiming her status as an interested party, instituted this proceeding before the Supreme Court.
• The petition sought to have the default judgment set aside on the ground that Mina was unjustly deprived of a hearing.
• In his answer, Jose Bona contended that the petition should not be maintained.

Issue:

Whether the defendant, Celestino Mina, was deprived of his right to be heard due to his failure to appear personally before the court, notwithstanding his written statements and doctor’s certificates.

• Consideration of whether his excuses of sickness (substantiated by medical documents) are sufficient grounds for non-appearance.
• Evaluation of whether his failure to secure legal representation to appear on his behalf constituted a valid basis for relief.

Whether the petition for setting aside the default judgment falls within the scope of section 513 of the Code of Civil Procedure.

• Determination of the applicability of section 513, which allows for relief if a party is unjustly deprived of a hearing due to fraud, accident, mistake, or excusable negligence.
• Assessment of whether the facts of the case qualify as a mistake of law or involve excusable negligence warranting the setting aside of the judgment.

• Whether the widow, as a person interested in the case, has sufficient standing to file the petition under the said provisions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)