Case Digest (G.R. No. 167880)
Facts:
Jack Arroyo v. Bocago Inland Dev't. Corp. (BIDECO), G.R. No. 167880, November 14, 2012, Supreme Court Third Division, Peralta, J., writing for the Court. The case was brought by a Petition for Review on Certiorari under Rule 45 of the Rules of Court.Petitioner Jack Arroyo (plaintiff below) filed a complaint for recovery of possession and damages on February 28, 1997 in the Regional Trial Court (RTC), Branch 56, Libmanan, Camarines Sur, asserting ownership of three parcels of land covered by TCT Nos. RT-854, RT-853 and RT-855 which he acquired in 1972 and on which he paid taxes and claimed were natural breeding grounds for crabs and prawns. Respondents were Bocago Inland Development Corporation (BIDECO), represented by Carlito Bocago, and the heirs of the late Ramon Bocago (Basilisa Vda. de Bocago, Carlito Bocago, Sannie Bocago Arrengo, and Inday Bueno), who were impleaded by amended complaint.
Respondents denied Arroyo’s right to possession, alleging prior and continuous possession since 1967 by Ramon Bocago and subsequent development and improvements made at Bocago’s expense; they argued agrarian reform exclusivity, prescription, laches and estoppel as defenses and counterclaimed for damages. Arroyo sent demand letters before filing suit. The parties exchanged pleadings; defendants repeatedly sought postponements and filed motions to set aside default when the RTC declared them in default for failure to appear at pre-trial and for not filing a pre-trial brief timely. The RTC admitted the amended complaint and served the newly impleaded heirs.
Because defendants failed to appear at scheduled hearings and other procedural dates, the RTC allowed plaintiff to present his evidence ex parte and, after such presentation, rendered judgment on October 15, 2001 in favor of Arroyo ordering respondents to vacate and return possession, to pay P2,581,560.00 as reasonable rentals and P100,000 as attorney’s fees. Both parties filed motions for reconsideration which the RTC denied on February 8, 2002.
Respondents appealed to the Court of Appeals (CA). The CA, in a decision promulgated November 18, 2004, upheld the RTC’s allowance of ex parte presentation (citing Section 5, Rule 18, Rules of Court) and agreed Arroyo was registered owner, but set aside the RTC judgment and dismissed Arroyo’s complaint on the ground of laches, finding that Arroyo ...(Pro-only)
Issues:
- Was Arroyo’s complaint barred by laches such that the Court of Appeals correctly dismissed his action?
- Was the RTC’s allowance of plaintiff’s ex parte presentation of evidence proper under the Rules of Court given respondents’ condu...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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