Case Digest (G.R. No. L-30370)
Facts:
The case involves Pedro Aducayen as the petitioner and Hon. Delfin V. Flores, Hon. David C. Concepcion, and Regal Sales Center, Inc. as the respondents. The events leading to this case began on January 23, 1968, when Regal Sales Center, Inc. filed a complaint for a sum of money against Simeon Figueras, Jr. and Pedro Aducayen in the Municipal Court of Makati, Rizal, presided over by Judge David C. Concepcion. Both defendants filed their written answers on February 27, 1968. The Municipal Judge scheduled a pre-trial for August 22, 1968, but only the counsel for the defendants appeared, as Aducayen was not notified of the pre-trial due to a telegram indicating Figueras was ill. On September 9, 1968, Aducayen received a decision from the Municipal Judge stating that he was in default for failing to appear at the pre-trial, despite not being informed of it. The judgment ordered Aducayen to pay Regal Sales Center, Inc. the amount of P644.45, plus interest. Subsequently, on Septembe...
Case Digest (G.R. No. L-30370)
Facts:
Filing of the Complaint: On January 23, 1968, respondent Regal Sales Center, Inc. filed a complaint for a sum of money against Simeon Figueras, Jr. and petitioner Pedro Aducayen in the Municipal Court of Makati, Rizal, presided by respondent Judge David C. Concepcion.
Answer Filed: Both petitioner Aducayen and defendant Figueras filed their written answer on February 27, 1968.
Pre-Trial Scheduling: Respondent Municipal Judge scheduled a pre-trial conference for August 22, 1968. However, petitioner was not notified of this pre-trial.
Ex-Parte Decision: On August 22, 1968, the Municipal Judge rendered a decision based solely on the evidence presented by the plaintiff, Regal Sales Center, Inc., declaring petitioner in default for failing to appear at the pre-trial. Petitioner was ordered to pay P644.45 with interest.
Amended Decision: On August 30, 1968, the Municipal Judge issued an amended decision, increasing the amount petitioner was ordered to pay to P2,090.00, again based on the same ex-parte evidence.
Certiorari Filed: Petitioner filed a petition for certiorari with the Court of First Instance, arguing that he was denied due process. The Court of First Instance dismissed the petition on January 25, 1969.
Supreme Court Petition: Petitioner filed a petition for review on certiorari with the Supreme Court on April 1, 1969.
Issue:
- Whether the Municipal Court's declaration of default and subsequent ex-parte decision violated petitioner's right to due process.
- Whether the Court of First Instance erred in dismissing the petition for certiorari despite the clear denial of procedural due process.
Ruling:
The Supreme Court granted the writ of certiorari, reversing the order of the Court of First Instance. The Court held that the Municipal Court's declaration of default and ex-parte decision were void due to the denial of procedural due process. The Court annulled the default order and the subsequent decisions, ordering a new trial where petitioner's right to be heard would be respected.
Ratio:
- (Unlock)