Case Digest (G.R. No. L-1523)
Facts:
Binan Transportation Company, Inc. (Petitioner) engaged in a legal battle with Fidel Ibanez and others (Respondents) initiated by a damage suit in the Court of First Instance of Laguna seeking P4,900 on May 30, 1940. Following an answer filed on June 3, 1940, the case faced delays due to the Japanese invasion which prevented both the petitioner and its counsel from attending the scheduled hearing on January 5, 1942. The trial occurred without the Petitioner’s presence on February 2, 1943, and a judgment was rendered on March 22, 1943. The Petitioner was never informed of this hearing or the decision. A series of events led to a petition for reconstitution of the case records filed on November 26, 1946, which was granted on December 20, 1946. The Petitioner claimed ignorance of the prior proceedings, subsequently filing motions for a new trial and for relief under Rule 37 and 38, but these motions were denCase 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.
Issues:
- 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:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)