Title
Tropical Homes, Inc. vs. Flores
Case
G.R. No. L-34057
Decision Date
Dec 19, 1980
The Supreme Court dismissed the case against Tropical Homes, Inc. for non-suit due to the plaintiff's absence at the pre-trial conference and corrected the lower court's written order.
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Case Digest (G.R. No. L-34057)

Facts:

  • The case involves Tropical Homes, Inc. and Benito Lapuz.
  • The case originated from a collection of a sum of money filed by Lapuz against Tropical Homes, Inc. in the Municipal Court of Makati, Rizal.
  • The municipal court rendered a decision in favor of Lapuz when Tropical Homes, Inc. failed to appear.
  • Tropical Homes, Inc. appealed the decision to the Court of First Instance of Rizal, Branch XI.
  • During the pre-trial conference, Lapuz and his counsel did not appear.
  • The court verbally dismissed the case for non-suit.
  • However, in its written order, the court declared Lapuz in default and ordered Tropical Homes, Inc. to present evidence.
  • Tropical Homes, Inc. pointed out the error to the court, arguing that the case should be considered as if filed directly with the Court of First Instance.
  • Tropical Homes, Inc. argued that if the plaintiff fails to appear, the case may be declared non-suited and dismissed.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Tropical Homes, Inc. and declared the ca...(Unlock)

Ratio:

  • In cases of appeal from a municipal court to the Court of First Instance, when the former was not yet a court of record, a trial de novo is required.
  • If the plaintiff fails to appear at the mandatory pre-trial conference, he...continue reading

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