G.R. No. 157219 - Bautista vs. Court of Appeals

On August 12, 1999, petitioners Natividad E. Bautista, Clemente E. Bautista, and Socorro L. Angeles filed a complaint for quieting of title before the RTC of Imus, Cavite, Branch 22, docketed as Civil Case No. 1948-99.
The complaint was later amended to implead additional respondents, namely Manila Papermills, International, Inc., Adelfa Properties, Inc., and the spouses Rodolfo and Nelly Javellana.
Petitioners alleged that they have been in actual and uninterrupted possession of Lot 5753 of the Imus Estate and discovered that the land was allegedly encumbered by a reconstituted title in the name of the respondents, which they claimed to be spurious.
Their primary prayer was to be declared the absolute owners of the disputed land.

After significant delays spanning more than two years, the case was eventually set for trial.
On May 2, 2002, petitioners filed an Urgent Motion for Postponement, stating that their lawyer, Atty. Michael Macaraeg, was in the United States attending to an important matter.
The trial court denied the motion for postponement, thereby considering petitioners to have waived the presentation of their evidence.
A Motion for Reconsideration filed by the petitioners was also denied.

Petitioners elevated the issue by filing a special civil action for certiorari with the Court of Appeals under CA-G.R. SP No. 72307 on the ground that the trial court’s denial of their motion for postponement resulted in a waiver of their rights.
They alleged that the trial court’s actions were tainted with bias and prejudice, noting that while their motion was denied, the court granted several continuances and postponements to the respondents on multiple occasions.
Petitioners contended that such arbitrary acts by the trial court deprived them of their constitutionally guaranteed right to due process.
They particularly stressed that denying their Urgent Motion for Postponement—especially when contrasted with the court’s disposition toward similar requests by respondents—manifested judicial partiality.

Petitioners argued that the trial court’s actions amounted to a grave abuse of discretion and a clear violation of due process.
They relied on precedents such as Padua vs. Ericta and Continental Leaf Tobacco [Phil.], Inc. vs. Intermediate Appellate Court to support the claim that being deprived of the chance to present evidence violates due process rights.

Whether the trial court committed grave abuse of discretion by denying the petitioners’ Urgent Motion for Postponement despite the counsel’s absence due to urgent matters abroad.
Whether the denial of the motion, in light of multiple postponements granted to respondents, constitutes judicial partiality and prejudice affecting petitioners’ right to due process.
Whether the failure to allow petitioners to present their evidence—after an explanation for the absence of counsel—amounts to a waiver of their constitutional right to be heard.
Whether the trial court’s decision to proceed with the trial despite petitioners’ request, amid contrasting treatment between the parties, is justified under the standard of judicial discretion.