Facts:

The case involves Proceso Flora as the plaintiff-appellant and Meliton Pajarillaga, Juanito Sabas, and Florentino C. Cariaso as the defendants-appellees. The events leading to this case began when Flora was served with a summons on February 13, 1964, in Civil Case No. 3316, filed by Juanito Sabas in the City Court of Cabanatuan City. Sabas sought to recover unpaid wages amounting to P2,147.30, along with P480.00 as differential pay for his work as a welder-mechanic in Flora's auto repair shop located in San Fernando, La Union. On March 5, 1964, Flora's lawyer, Atty. Manalo D. Cacanindin, filed a motion to dismiss the case, citing improper venue and the pendency of another action regarding the same matter before the Labor Attorney's office in San Fernando. However, this motion was only received by the Cabanatuan court on March 18, 1964.

In the meantime, the Cabanatuan court scheduled a hearing for March 23, 1964, due to Flora's failure to file an answer. On ...

Facts:

Background of the Case

• Plaintiff-appellant Proceso Flora filed a complaint to annul the judgment rendered by the City Court of Cabanatuan City in Civil Case No. 3316, where he was declared in default and ordered to pay unpaid wages and differential pay to Juanito Sabas, a welder-mechanic in Flora's auto repair shop.

Service of Summons and Motion to Dismiss

• Flora was served with summons on February 13, 1964.
• On March 5, 1964, Flora's lawyer, Atty. Manalo D. Cacanindin, filed a motion to dismiss via registered mail, citing improper venue and the pendency of a labor case between the parties in San Fernando, La Union.
• The motion was received by the Cabanatuan court on March 18, 1964.

Default Declaration and Judgment

• On March 10, 1964, the Cabanatuan court issued an order setting the case for hearing on March 23, 1964, as Flora had not filed an answer.
• On March 13, 1964, the court declared Flora in default and allowed Sabas to present evidence ex parte.
• A copy of the default order was sent to Flora by registered mail on March 16, 1964, but it was returned unclaimed on May 6, 1964.
• On March 23, 1964, the court rendered a judgment against Flora, which was also sent by registered mail but returned unclaimed on May 27, 1964.

Denial of Motion to Dismiss and Motion to Lift Default

• On March 19, 1964, the court denied Flora's motion to dismiss.
• On April 13, 1964, Flora filed a motion to lift the order of default, citing excusable neglect, a valid defense, and improper venue. This motion was denied on May 2, 1964.

Filing of Annulment Complaint

• Flora filed a complaint for annulment in the Court of First Instance of La Union on July 10, 1964, 109 days after the default judgment was rendered.
• The trial court dismissed the complaint, citing improper venue and the validity of the proceedings leading to the default judgment.

Issue:

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Ruling:

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Ratio:

1. Improper Venue: The annulment complaint should have been filed in Nueva Ecija, where the default judgment was rendered, as the proper remedy was a petition for relief under Rule 38 of the Rules of Court.
2. Validity of Default Judgment: Flora was in default when he filed his motion to dismiss, and the court acted within its authority in declaring him in default and rendering judgment ex parte.
3. Notice of Judgment: The judgment was sent to Flora by registered mail, and his failure to claim it did not invalidate the judgment.
4. Labor Case Considerations: The Court emphasized that labor cases should be resolved in favor of the laborer, especially given the prolonged nature of the dispute.

Conclusion:

The Supreme Court affirmed the dismissal of Flora's complaint, holding that the default judgment was valid and that Flora failed to avail himself of the proper legal remedies within the required timeframes.