Facts:

This case involves Mamerta Banal as the plaintiff and appellee, and Jose Safont et al. as the defendants and appellants. The trial began in July 1903 at the Court of First Instance of Pampanga. On February 15, 1907, a judgment was rendered against the appellants. Following this, the appellants filed a motion to reverse the judgment and request a new trial, claiming they had uncovered important evidence too late for the original hearing and some evidence that only came to light after the trial had concluded. They asserted that this new evidence could significantly alter the case's outcome in their favor. However, the appellee objected to the admission of this new evidence and the motion. The appellants failed to demonstrate attempts to introduce the purported evidence during the original trial, nor did they seek remedies to avoid any perceived injuries prior to the court's decision. Section 497 of the Code of Procedure in Civil Actions expressly permits the Supreme Court

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Facts:

Background and Parties

• Plaintiff and Appellee: Mamerta Banal.
• Defendants and Appellants: Jose Safont et al.

Trial and Proceedings

• The trial commenced in July 1903 in the Court of First Instance of Pampanga.
• The trial concluded with a judgment dated February 15, 1907, which was subsequently appealed by the defendants.

Motion for New Trial

• After being furnished with the printed bill of exceptions, the appellants filed a written motion before submitting their brief.
• The motion requested the reversal of the judgment and the granting of a new trial on the ground that important evidence had been secured.
• The evidence in question comprised documents (books and receipts) that, according to the appellants, could not be produced on time due to unforeseen and inevitable causes, or because they were discovered after the trial had ended.

Handling of Evidence and Documents

• Documents were exhibited, and varied forms of evidence were taken during the trial proceedings.
• A notice to produce the books had been issued to one of the appellants as early as June 2, 1906, yet no mention was made at trial of any impossibility in producing these books.
• The books and receipts were carefully removed from Pampanga to Spain, highlighting the parties’ awareness of their value and importance.
• The existence of these documents was known from as early as July 9, 1903, when the parties were summoned and served with a copy of the complaint.

Procedural Context and Conduct of the Parties

• Over more than three years, extensive discussions on business and accounting matters took place between the parties and their principals.
• The evidence allegedly omitted was in the possession of the appellants, and no legal remedy was sought before the trial concluded.
• The appellants’ failure to produce the documents during trial was attributed to their unwillingness, as opposed to any genuine inability or accident.

Legal Provisions Invoked

• Section 497 of the Code of Procedure in Civil Actions was cited.
• This section allows for the submission of new and material evidence, discovered by due diligence, that could not have been presented at trial, as a basis for a new trial or a reformed judgment.

Issue:

Whether the books and receipts claimed to be new evidence could be classified as such, given that the appellants had prior knowledge and access to them.

• Did the documents meet the criteria of being "new and material evidence" under Section 497?
• Were the circumstances presented by the appellants sufficient to demonstrate that the evidence could not have been produced at the trial?

Whether the appellants’ failure to produce the documents during the trial was justified by unforeseen and inevitable circumstances.

• Could the appellants have, with due diligence, produced the documents despite any alleged difficulties?
• Does the prior notice to produce and the lengthy duration of the trial undermine the claim of unforeseen circumstances?

The propriety of granting a new trial based on the motion filed in the absence of explicit conditions and circumstances justifying the late production of evidence.

• Does the motion conform to the strict conditions required by law for a new trial?
• Is the granting of a new trial appropriate when the evidence was known and available to the parties from the outset of the proceedings?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)