Case Digest (G.R. No. L-38807)
Facts:
The case involves Doroteo F. Bala and several other petitioners, including Remedios B. Florita, Manuel Bala, Loreto B. Sahagun, Rodolfo Bala, Doroteo M. Bala, Jr., and Esperanza B. Guiang, as petitioners against Manuel V. Romillo, Jr., in his capacity as Judge of the Court of First Instance of Laoag, Mariano Bala, and Rafaela Vda. de Aquino as respondents. The events leading to this case began in 1939 when the spouses Gregorio Bala and Antonia Factora passed away intestate, leaving behind multiple heirs and extensive landholdings in Ilocos Norte. For years, the heirs divided the produce of the land among themselves until 1960, when Doroteo F. Bala claimed exclusive ownership of 22 parcels of land. This claim led to a complaint filed by Rafaela Bala Vda. de Aquino, Agapito Bala, and Mariano Bala against Doroteo F. Bala and the heirs of their half-sister, Melchora Racela, for the partition of 39 parcels of land located in Solsona, Banna, and Laoag, Ilocos Norte. The trial court...
Case Digest (G.R. No. L-38807)
Facts:
Background of the Case
- The case involves the estate of the deceased spouses Gregorio Bala and Antonia Factora, who died intestate in 1939, leaving extensive landholdings in Ilocos Norte.
- Their heirs, including petitioners and respondents, initially divided the produce of the land among themselves until 1960, when petitioner Doroteo F. Bala took possession of 22 parcels of land, claiming them as his exclusive property.
Initiation of Legal Proceedings
- In 1960, Rafaela Bala Vda. de Aquino, Agapito Bala, and Mariano Bala filed a complaint against Doroteo F. Bala and the heirs of their half-sister, Melchora Racela, seeking the partition of 39 parcels of land.
- The parties submitted a compromise agreement in 1965, adjudicating undisputed parcels of land (Items 23 to 39) among themselves, leaving 22 parcels in dispute.
Trial and Decision
- The trial court appointed a receiver for the disputed parcels and proceeded with the trial.
- On November 23, 1967, the trial court considered the case submitted for decision after only the plaintiffs and their counsel appeared, despite proper notice to the defendant’s counsel.
- On December 15, 1967, the court ruled that the disputed parcels were common undivided property and ordered their partition. Doroteo F. Bala was also ordered to account for the produce of the land from 1961-1966.
Post-Decision Proceedings
- Doroteo F. Bala filed a motion for reconsideration, claiming lack of notice and the existence of new evidence, but the motion was denied.
- He appealed to the Court of Appeals, which dismissed the appeal for being untimely.
- The trial court appointed commissioners to effect the partition, but Doroteo F. Bala failed to nominate his commissioner.
- The commissioners’ report was approved, and a writ of execution was issued.
- Doroteo F. Bala filed multiple motions to quash the writ and oppose the partition, all of which were denied.
Petition to Annul the Decision
- On June 20, 1974, Doroteo F. Bala and other petitioners filed a petition to annul the trial court’s decision and subsequent orders, alleging lack of notice and deprivation of their day in court.
Issue:
- Whether the trial court erred in considering the case submitted for decision despite the alleged lack of notice to Doroteo F. Bala and his counsel for the November 23, 1967 hearing.
- Whether the trial court’s decision and subsequent orders were valid, given the claims of deprivation of due process.
- Whether the disputed parcels of land are the common undivided property of the parties or the exclusive property of Doroteo F. Bala.
Ruling:
The Supreme Court dismissed the petition, upholding the trial court’s decision and subsequent orders. The Court found that:
- Doroteo F. Bala and his counsel were properly notified of the November 23, 1967 hearing, as evidenced by the postmaster’s notices.
- The trial court did not abuse its discretion in considering the case submitted for decision after the plaintiffs rested their case and the defendant failed to appear.
- Doroteo F. Bala’s claims of lack of notice and deprivation of due process were unsubstantiated and untimely, as he had already exhausted his remedies by appealing to the Court of Appeals.
- The disputed parcels of land were correctly declared as common undivided property of the parties.
Ratio:
- Service of Notice: Under Section 8, Rule 13 of the Revised Rules of Court, service by registered mail is deemed complete upon actual receipt or after five days from the first notice by the postmaster. Since the notice was sent to Doroteo F. Bala’s counsel at his address of record and postmaster notices were issued, service was valid.
- Discretion of the Trial Court: The trial court has discretion to proceed with the case if a party fails to appear despite proper notice. Absent a showing of abuse of discretion, the court’s actions will not be overturned.
- Finality of Judgment: Doroteo F. Bala’s failure to timely raise the issue of lack of notice in the Court of Appeals precludes him from raising it later. Allowing such belated challenges would lead to endless litigation.
- Common Ownership: The disputed parcels of land were properly declared as common undivided property, as the evidence supported the plaintiffs’ claim of co-ownership.