G.R. No. 48859 - Valdez vs. Jugo

The case involves Emiliano J. Valdez as petitioner versus Fernando Jugo, Judge of First Instance of Manila, and other respondents.
The petition was brought before the Supreme Court as both appeal and error arising from issues in the lower court proceedings.

Petitioner filed a motion for new trial which failed to comply with the specific requirements set forth under the new rules, notably Rule 37, section 2, third paragraph.
The rule mandates that the motion must "point out specifically the findings or conclusions of the judgment which are not supported by the evidence or which are contrary to law," with express reference to the testimonial or documentary evidence or the provisions of law in question.

The petitioner's motion omitted the detailed specification required by the rule.
Due to the absence of these essential details, the motion was treated as a mere pro-forma effort designed to delay the proceedings.

The motion for new trial was filed on November 22, 1941, and was set for hearing on December 20, 1941.
In his oral arguments, the petitioner admitted he needed time to study the transcript and find reasons to support the grounds of his motion, indicating that he filed the motion without certainty about its merits.
Additionally, when questioned why he did not follow up on his motion given that he was in Manila with courts already in session, he confessed a lack of interest in speeding up the proceedings, revealing his status as the defeated party and a clear intent to delay.

The petitioner was represented by Felix B. Bautista, while the respondent counsel for other parties included Gregorio Perfecto and teams from Central Luzon Milling Co., P. J. Dayrit, and Bengson & Magsanoc.
The case reached the Supreme Court originally on an action for mandamus, with the decision penned by Associate Justice Manuel V. Moran.

The Court singled out the pro-forma motion as offensive to the new procedural rules, holding that it did not and could not interrupt the appeal period.
Furthermore, the Court noted that the petitioner’s actions were a deliberate attempt to delay the proceedings for his own convenience and denied him any equitable relief.

Does a motion for new trial that fails to state specific reasons as required under Rule 37 interrupt the period for appeal?
Can a pro-forma motion be valid when it merely attempts to delay the proceedings without meeting the statutory demands?

Was the timing and manner of the petitioner's filing indicative of an intention to delay the judicial process?
Should courts grant equitable relief when a motion is found to be a deliberate tactic for delaying proceedings?