Title
Bernabe vs. Geraldez
Case
G.R. No. L-39721
Decision Date
Jul 15, 1975
Braulio Bernabe appealed a forcible entry ruling; the Court of First Instance affirmed without a trial de novo, citing finality under RA 6031 and sufficient compliance with constitutional decision requirements.
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Case Digest (G.R. No. L-39721)

Facts:

  1. Parties Involved:

    • Petitioner: Braulio Bernabe
    • Respondents: Hon. Ambrocio M. Geraldez (Presiding Judge, Court of First Instance of Bulacan), E. German Cruz, Jr. (Deputy Sheriff of Bulacan), and Jose Legaspi (prevailing party).
  2. Nature of the Case:

    • The case originated from a forcible entry case filed against Braulio Bernabe in the Municipal Court of Norzagaray, Bulacan. The municipal court ruled against Bernabe, ordering him to vacate the disputed premises, remove the house under construction, and pay P500 as attorney’s fees.
  3. Appeal to the Court of First Instance:

    • Bernabe appealed the municipal court’s decision to the Court of First Instance of Bulacan. However, no trial de novo (new trial) was conducted. Instead, the respondent judge reviewed the records of the case, including testimonial and documentary evidence, and affirmed the municipal court’s decision.
  4. Petitioner’s Argument:

    • Bernabe argued that the respondent judge erred in not conducting a trial de novo and in affirming the municipal court’s decision without allowing him to present additional evidence. He also claimed that the decision failed to comply with the constitutional requirement that every decision must clearly and distinctly state the facts and the law on which it is based.
  5. Respondent Judge’s Decision:

    • The respondent judge found no reason to disturb the municipal court’s findings, emphasizing that the trial court’s findings command great respect and should not be disturbed merely because the appellant is dissatisfied. The judge also noted that Bernabe failed to submit a memorandum pointing out specific errors in the municipal court’s decision.

Issue:

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Ruling:

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Ratio:

  1. Finality of Decisions in Appeals from Municipal Courts:

    • Under Republic Act No. 6031, decisions of the Court of First Instance in cases appealed from municipal or city courts are final. There is no requirement for a trial de novo, and the appellate court may decide the case based on the records of the lower court.
  2. Compliance with Constitutional Requirements:

    • A court decision satisfies the constitutional requirement if it clearly explains why a party prevailed under the applicable law and established facts. There is no rigid formula for the language used, as long as the parties understand the basis for the decision.
  3. Respect for Lower Court Findings:

    • The findings of the trial court command great respect and should not be disturbed unless there is a clear showing of error. Mere dissatisfaction with the decision is not sufficient to warrant a reversal.
  4. Opportunity to Present Evidence:

    • A party must present all relevant evidence during the trial in the lower court. Failure to do so cannot be remedied by requesting a trial de novo on appeal.


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