Facts:

On September 16, 1949, Joseph Arcache (the plaintiff) initiated an action for ejectment and the collection of overdue rentals against B.S. Chainani (the defendant) in the Municipal Court of Manila. The plaintiff sought not only the outstanding rent but also attorney's fees and costs associated with the proceedings. On March 9, 1951, the court ruled in favor of Arcache, ordering Chainani to pay the claimed amount while dismissing Chainani's counterclaims. Reacting to this judgment, Chainani appealed to the Court of First Instance of Manila. On April 30, 1951, he filed an answer reiterating his previous defense and asserting a significant counterclaim, claiming that Arcache owed him ₱25,000 plus interest, as substantiated by a promissory note included with his answer. A reply from Arcache followed, and the case was set for hearing on July 26, 1951. However, this hearing was canceled, and notice of a rescheduled hearing for May 7, 1953, was sent on April 26, 1953. When the

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Facts:

Initiation of the Case

• On September 16, 1949, Joseph Arcache, the plaintiff, filed an action for ejectment and collection of rentals, plus attorney’s fees and costs, before the Municipal Court of the City of Manila.
• The subject property was located within the City of Manila.

Trial Court Proceedings

• After due hearing, on March 9, 1951, the Municipal Court rendered judgment in favor of the plaintiff ordering the defendant to pay the amount claimed, while dismissing defendant’s counterclaim.
• Defendant B. S. Chainani appealed from the decision to the Court of First Instance of Manila.
• On April 30, 1951, the defendant filed his answer—which essentially reproduced the answer filed earlier—with a key affirmative defense alleging that the plaintiff was indebted to him in the sum of P25,000, plus interest, as evidenced by a promissory note attached to the answer.
• Plaintiff subsequently filed a reply to the defendant’s answer.

Rescheduling and Trial Anomalies

• The case was initially set for hearing on July 26, 1951; however, that session was cancelled.
• On April 26, 1953, both parties were notified that the trial was postponed to May 7, 1953, at 1 o’clock in the afternoon.
• On the scheduled day, when the trial commenced, defendant and his counsel did not appear.
• As the hearing continued, plaintiff began presenting his evidence.

Motion for Postponement

• During the trial, just as the first witness was about to testify, Atty. Manuel B. Pineda—who identified himself as an assistant in the law office of the defendant’s counsel—appeared to inform the court that a motion for postponement had been filed at 12:20 o’clock that afternoon.
• The trial judge reviewed the motion, heard the brief explanation, and ultimately declared the motion without merit, thus allowing the hearing to proceed.

Judgment and Subsequent Motion for New Trial

• After the trial concluded, the trial judge rendered judgment ordering the defendant to pay the plaintiff P25,125, along with P100 for attorney’s fees and the cost of the action.
• On June 10, 1953, the defendant filed a motion for a new trial arguing that his counsel’s failure to appear was due to excusable negligence.
• The motion asserted that the absence was attributable to:
• An order from the Court of First Instance of Batangas, received on May 6, 1953, enjoining counsel to appear at a criminal trial (People vs. Arguelles, et al.) scheduled for the same day.
• The urgent requirement to file a motion for postponement, which was delayed due to miscommunication between Atty. Pineda and the counsel’s secretary.
• Plaintiff opposed the motion in writing.
• On June 23, 1953, the Court of First Instance of Manila denied the motion for a new trial on the ground of lack of merit.
• The case eventually reached the Court of Appeals and was then elevated to the Supreme Court as it involved a pure question of law.

Issue:

Whether the counsel’s failure to appear at the trial on May 7, 1953, due to conflicting court orders and the ensuing delay in filing a motion for postponement, constitutes excusable negligence.

• Did the conflicting obligations—specifically, the order from the Court of First Instance of Batangas to attend a criminal trial—justify the non-appearance in the civil trial?
• Was the delayed filing of the motion for postponement, caused by miscommunication within the defendant’s legal team, sufficient grounds to grant a new trial?

Whether granting a new trial in this context would prevent a miscarriage of justice and avoid undue prejudice to the adverse party, considering that:

• The defendant’s counsel acted under external compulsion and had a meritorious defense backed by a promissory note.
• The legal rules on adjournments and postponements are discretionary and should consider the peculiar circumstances of conflicting trial dates and orders.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)