Case Digest (G.R. No. L-1523)
Facts:
The case involves Binan Transportation Company, Inc. as the petitioner and Fidel Ibanez, among others, as the respondents. The events leading to this case began when the petitioner was sued for damages amounting to P4,900 in the Court of First Instance of Laguna on May 30, 1940. The petitioner filed an answer to the complaint on June 3, 1940, and a hearing was scheduled for January 5, 1942. However, due to the Japanese invasion, the petitioner and its counsel were unable to attend the hearing. The trial proceeded without them on February 2, 1943, and the petitioner was not notified of this hearing or the subsequent admission of amendments to the complaint. A decision was rendered on March 22, 1943, but again, no notice was served to the petitioner regarding this decision.
After the war, on November 26, 1946, a petition for the reconstitution of the case records was filed, which was granted on December 20, 1946. The petitioner learned of the decision only after the reconstit...
Case Digest (G.R. No. L-1523)
Facts:
Background of the Case:
- The petitioner, Binan Transportation Company, Inc., filed a petition for certiorari against the respondents, including Judge Fidel Ibañez, challenging the order of execution dated June 28, 1947, of a judgment rendered by the Court of First Instance of Laguna on March 22, 1943.
- The petitioner argued that the judgment was null and void because it had not been notified of the hearing or the rendition of the decision.
Reconstitution of Records:
- The records of the case were lost or destroyed during the Philippine liberation. Upon motion by the plaintiffs (respondents), the Court of First Instance of Laguna ordered the reconstitution of the pleadings and the decision on December 20, 1946.
- The petitioner claimed it only became aware of the decision after its reconstitution and filed motions for new trial and relief under Rules 37 and 38, which were denied by the respondent judge for being filed out of time.
Key Dates and Proceedings:
- The decision was originally rendered on March 22, 1943.
- The reconstitution of the decision was ordered on December 20, 1946.
- The petitioner filed motions for new trial and relief on January 22, 1947, and May 20, 1947, respectively, both of which were denied.
- An alias writ of execution was issued on June 28, 1947.
Petitioner’s Allegations:
- The petitioner alleged that it was not notified of the trial, the amendments to the complaint, or the rendition of the decision.
- It argued that the lack of notice deprived the court of jurisdiction, rendering the decision null and void.
Respondent’s Position:
- The respondent judge contended that the petitioner was constructively served notice of the decision on December 20, 1946, during the reconstitution process.
- The respondent also argued that the motions for relief were filed out of time.
Issue:
Jurisdiction and Due Process:
- Whether the trial court had jurisdiction to render the decision on March 22, 1943, given the alleged lack of notice to the petitioner regarding the trial and the decision.
- Whether the petitioner was denied due process by not being notified of the hearing and the decision.
Validity of the Reconstituted Decision:
- Whether the reconstitution of the decision on December 20, 1946, constituted constructive notice to the petitioner.
- Whether the reconstituted decision could be considered valid if the original decision was rendered without proper notice.
Timeliness of Motions for Relief:
- Whether the petitioner’s motions for new trial and relief were filed within the prescribed period under the Rules of Court.
- Whether the denial of these motions by the respondent judge was proper.
Propriety of Certiorari:
- Whether certiorari is the appropriate remedy given the availability of an appeal.
Ruling:
The Supreme Court denied the petition for certiorari, holding that:
Presumption of Regularity:
- The Court upheld the presumption that official duties were regularly performed and that the law was obeyed, meaning the petitioner was presumed to have been notified of the trial and the decision.
- The petitioner failed to rebut this presumption with sufficient evidence.
Denial of Motions for Relief:
- The respondent judge correctly denied the motions for new trial and relief because they were filed outside the period prescribed by Rule 38 of the Rules of Court.
- The proper remedy for the petitioner would have been an appeal, not certiorari.
Jurisdiction of the Trial Court:
- The Court found no grave abuse of discretion or excess of jurisdiction by the respondent judge in issuing the order of execution.
- The trial court had jurisdiction to grant or deny the motions, and its decision could only be reviewed on appeal.
Dissenting Opinion:
- Justice Perfecto dissented, arguing that the lack of notice to the petitioner deprived the trial court of jurisdiction, rendering the decision null and void.
- He contended that the petitioner was denied due process and that the decision should be declared void ab initio.
Ratio:
Presumption of Regularity:
- Under Section 69(m) and (ee) of Rule 123, there is a presumption that official duties have been regularly performed and that the law has been obeyed. This presumption applies unless rebutted by clear evidence.
Timeliness of Motions for Relief:
- Motions for relief under Rule 38 must be filed within 60 days from the time the petitioner learns of the judgment and not more than six months after the judgment was entered. Failure to comply with these timelines renders the motions untimely.
Proper Remedy:
- Certiorari is not the appropriate remedy when an appeal is available. The petitioner should have appealed the denial of its motions instead of filing a petition for certiorari.
Due Process and Jurisdiction:
- The majority held that the petitioner was constructively notified of the decision during the reconstitution process, satisfying due process requirements.
- The dissenting opinion emphasized that the lack of notice deprived the court of jurisdiction, rendering the decision void ab initio.