Facts:

The case involves Gil Buendia as the plaintiff and appellee and Vicente Sotto as the defendant and appellant. The appeal originated from a decision rendered by the Court of First Instance of Manila on June 14, 1937, following a prior judgment on March 16, 1937. The court initially ruled in favor of Buendia,ordering Sotto to pay P 1,573.26, with legal interest and costs. On April 22, 1937, Buendia filed a "Motion for Reconsideration and Reopening of Trial," alleging that crucial financial factors were omitted from the initial decision. In this motion, Buendia highlighted errors in the judgment, including the improper deduction of P 567.50 for legal interest and P 60.12 for costs, both of which he claimed were inadvertently deducted twice. He also pointed out that P 400, as specified in Exhibit A, had already been paid to Sotto. The lower court, upon accepting the motion for reconsideration and reopening, amended its initial ruling and ordered Sotto to pay an increased a

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Facts:

Procedural History and Case Background

• The case involves plaintiff and appellee Gil Buendia and defendant/appellant Vicente Sotto.
• The action arose from a complaint filed on or around November 21, 1936, seeking monetary relief from defendant, notably with interests and costs attached.
• On March 16, 1937, the Court of First Instance of Manila rendered a judgment siding with the plaintiff, sentencing the defendant to pay a sum of P1,573.26 with legal interest from the filing date (or November 21, 1936) plus the costs.
• Subsequent to the judgment, on April 22, 1937, plaintiff Gil Buendia, through his attorneys, filed a “Motion for Reconsideration and Reopening of Trial” accompanied by annexes labeled A, B, C, and D.
• The motion alleged that:
• Certain amounts, namely P567.50 as legal interest and P60.12 as costs, had been erroneously deducted twice from the amount adjudicated.
• The sum of P400 already paid to Atty. Vicente Sotto (as evidenced by the annexes) was mistakenly included in the stipulation of facts for the trial court’s decision.
• The lower court, after receiving the motion and the annexes (despite the motion not being accompanied by duplicate copies for the defendant), granted the motion.
• On June 14, 1937, the trial court amended its earlier judgment and ordered the defendant to pay an increased sum of P2,600.88 with legal interest extending from the same date and plus costs.

Allegations of Error Raised on Appeal

• The defendant/appellant Vicente Sotto challenged the trial court’s ruling on the basis of seven alleged errors.
• Two of these errors raised questions of procedure:
• Error IV: The trial court allegedly erred in not striking out the plaintiff’s motion for reconsideration and reopening of trial for improper filing, as it was not in strict accordance with the Rules of the Courts of First Instance (specifically paragraph 18).
• Error V: The trial judge purportedly erred by considering and deciding the motion without setting it for trial and without giving the defendant an opportunity to be heard.

Factual and Documentary Evidence

• The motion submitted by plaintiff contained attachments (annexes A, B, C, and D) that purportedly established that the sum of P400 had already been paid to Atty. Vicente Sotto.
• Notice of the motion was served on the defendant, however, the copies of the supporting annexes were not sent with the notice.
• The lower court, despite these procedural irregularities, reconsidered its March 16 judgment and rendered an amended decision, which ultimately became the subject of the appeal.

Issue:

Whether the trial court erred in considering the plaintiff's motion for reconsideration despite its notice to the adverse party not being accompanied by copies of the attached annexes.

• Does the absence of copies of annexes A, B, C, and D in the notice vitiate the validity of the motion for reconsideration and the subsequent amended judgment?
• What is the proper application of the rules regarding notice and the strict compliance with the procedural requirements prescribed by the Rules of the Courts of First Instance?

Whether the trial court committed an error by deciding the plaintiff’s motion for reconsideration and reopening of trial without formally setting the motion for trial or affording the defendant the opportunity to be heard.

• Does the failure to hear the defendant before amending the judgment violate the due process rights of the defendant, particularly the right not to be deprived of property without due process?
• Can the amendment of a judgment in the absence of a proper hearing and trial be considered valid under the provisions of the Code of Civil Procedure and the Constitution?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)