Title
Supreme Court
Lagon vs. Velasco
Case
G.R. No. 208424
Decision Date
Feb 14, 2018
A borrower challenged the Judicial Affidavit Rule, claiming it violated due process by requiring pre-trial submission of evidence; the Supreme Court upheld the rule, emphasizing its role in expediting proceedings and ensuring orderly justice.

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)

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