Facts:

• Two consolidated cases were heard jointly in the Court of First Instance of Laguna due to similar facts and a single defendant, Marcos Pulutan.
• Plaintiffs: Epifanio Guia and Crispin Bakod.
• The cases were elevated to the Court of Appeals and then to the Supreme Court after the abolition of the Court of Appeals and the re-establishment of the Commonwealth Government post-Japanese occupation.

First Case (CA-R.G. No. 421 and No. 7115):

• Epifanio Guia bought uncultivated land from Pulutan, planted coconut trees, increasing its value to P1,250.
• The land was part of a larger parcel under Torrens Title No. 10287 in Laguna.
• Guia also exchanged another piece of land valued at P1,980 with Pulutan, which was also part of the same larger parcel.
• Spencer, Kellog & Sons Inc. won a lawsuit over the title of the larger parcel, causing Guia to lose both pieces of land.
• Guia demanded compensation from Pulutan under the rule of eviction and warranty, but Pulutan ignored these demands.

Second Case (CA-R.G. No. 422 and No. 7153):

• Crispin Bakod bought uncultivated land from Pulutan, planted coconut trees, increasing its value to P4,410.80.
• This land was also part of the larger parcel and was lost in the lawsuit against Spencer, Kellog & Sons Inc.
• Bakod demanded compensation from Pulutan under the rule of eviction and warranty, but Pulutan ignored these demands.

Pulutan's Defense:

• Claimed the deeds of sale and exchange did not reflect the true agreement.
• Asserted he did not receive any payment or valuable consideration.
• Argued plaintiffs became owners through a coconut planting contract.
• Executed deeds to facilitate land subdivision and enable plaintiffs to obtain titles.
• Plaintiffs were aware the lands were part of a larger parcel and titled in another's name.
• Plaintiffs' negligence in securing titles led to their loss in the lawsuit.
• Compensation demanded was excessive and the matter was res judicata.

Court Proceedings:

• Heard on August 24, 1942, with only plaintiffs present; defendant and his lawyer were absent.
• Judge proceeded with the hearing, assuming abandonment by the defendant.
• Decision issued in favor of plaintiffs.
• Defendant, with a new lawyer, requested a new hearing, citing lack of notification and detention by Japanese military police.
• Judge denied the request and issued the final decision on September 2.
• Defendant's motion for reconsideration was denied, leading to the present appeal.

Issue:

• (Unlock)

Ruling:

1. Yes, the Court of First Instance erred in proceeding with the hearing and issuing a decision in the absence of the defendant and his lawyer.
2. Yes, the def...(Unlock)

Ratio:

• The Supreme Court emphasized judicial effic...continue reading