Title
Beltran vs. Cabrera
Case
G.R. No. 48109
Decision Date
Sep 7, 1942
The Supreme Court held that a plaintiff's non-appearance at a new trial does not justify case dismissal, thereby reversing the dismissal order and remanding for further proceedings.
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Case Digest (G.R. No. 48109)

Facts:

  • Natalia Beltran filed a case against Cirilo Mapa for a sum of money.
  • On November 7, 1940, the Municipal Court of Manila ruled in favor of Beltran.
  • Mapa filed a motion for reconsideration and a new trial on November 16, 1940, claiming the judgment lacked evidence and was contrary to law.
  • The Municipal Court granted Mapa's motion on December 28, 1940.
  • Beltran sought to set aside the December 28 order and requested execution of the November 7 judgment on January 20, 1941.
  • The court denied Beltran's motions and scheduled a new trial for February 8, 1941.
  • Beltran initiated certiorari proceedings in the Supreme Court to annul the December 28 order and restrain the new trial.
  • The respondent judge dismissed Beltran's complaint due to her non-appearance at the new trial.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the Municipal Court's order granting a new trial.
  • The Court reversed the dismissal of Beltran's complaint for her n...(Unlock)

Ratio:

  • The Supreme Court cited Rule 4, Section 16 of the new Rules of Court, which permits a municipal court to grant a new trial to rectify errors or injustices.
  • This aligns with the precedent set in Veluz vs. Justice of the Peace of Sariaya, affirming a court's inherent power to amend its orders for justice.
  • A new trial does not require new evidence but rather a reconsideration of existing evidence.
  • The absence of parties at the new trial does not preclude ...continue reading

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