Case Digest (G.R. No. 208424) Core Legal Reasoning Model
Facts:
In Armando Lagon v. Hon. Dennis A. Velasco (G.R. No. 208424, February 14, 2018), petitioner Armando Lagon obtained a cash loan of PHP 300,000.00 from private respondent Gabriel Dizon in December 2000, issuing a postdated PCIBank Check for the same amount which was later dishonored for insufficient funds. After Lagon refused Dizon’s demand letter dated May 6, 2011, Dizon filed a Complaint for Sum of Money, Damages, and Attorney’s Fees on June 6, 2011 in the Municipal Trial Court in Cities of Koronadal, South Cotabato. Lagon moved to dismiss on prescription grounds on October 8, 2011; Dizon subsequently amended his complaint to include two demand letters sent via JRS Express on March 23, 2010 and May 6, 2011. Lagon filed his Answer on February 29, 2012, alleging full payment. During pre-trial, both parties were directed to file pre-trial briefs and, pursuant to the Judicial Affidavit Rule (A.M. No. 12-8-8-SC), to submit judicial affidavits and documentary evidence five days befor
Case Digest (G.R. No. 208424) Expanded Legal Reasoning Model
Facts:
- Antecedent Transaction and Demand
- December 2000: Petitioner Armando Lagon obtained a cash loan of ₱300,000.00 from private respondent Gabriel Dizon and issued PCIBank Check No. 0064914, postdated January 12, 2001.
- January 2001: The check was dishonored for insufficient funds.
- May 6, 2011: Dizon sent a demand letter for payment; Lagon refused.
- Trial Court Proceedings
- June 6, 2011: Dizon filed a Complaint for Sum of Money, Damages, and Attorney’s Fees against Lagon.
- October 8, 2011: Lagon moved to dismiss on prescription grounds; Dizon opposed and amended his complaint, alleging two demand letters (March 23, 2010 and May 6, 2011).
- February 29, 2012: Lagon filed an Answer claiming he paid the loan.
- August 9, 2012: The Municipal Trial Court in Cities of Koronadal (Judge Velasco) issued a Pre-Trial Conference Order directing pre-trial briefs.
- Assailed Orders on Judicial Affidavits
- June 6, 2013: At the initial trial, neither party submitted judicial affidavits. Judge Velasco fined the plaintiff ₱3,000, awarded the defendant ₱5,000 for costs, and ordered both parties to file judicial affidavits five days before trial or face inadmissibility.
- June 26, 2013: Lagon received the order; June 27, 2013: he filed a Motion for Partial Reconsideration arguing that Section 2 of the Judicial Affidavit Rule violates due process and conflicts with the rule on Demurrer to Evidence.
- July 10, 2013: Judge Velasco denied the motion, holding that the Rule does not violate due process.
- Thereafter, Lagon filed a Petition for Certiorari under Rule 65 before the Supreme Court.
Issues:
- Whether Section 2 of the Judicial Affidavit Rule—which requires both parties to submit judicial affidavits and documentary evidence before pre-trial—violates the defendant’s right to due process and conflicts with the rule on Demurrer to Evidence and the prescribed order of trial.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)