G.R. No. L-4917 - Vda. de Miranda

Plaintiff: Remedios M. Vda. de Miranda, who filed an action to recover possession of two parcels of land in Paco, City of Manila, along with the collection of monthly rental payments amounting to P1,200 from January 1946 until recovery of the land.
Defendants: A group totaling forty-nine (49) individuals, with Urbano Legaspi as one of the principal parties, who were alleged to be unlawfully occupying the land.

On May 3, 1949, the plaintiff initiated the action by filing the complaint in court.
On May 21, 1949, the defendants filed a motion requesting either a detailed bill of particulars or the dismissal of the complaint, as well as a motion for the suspension of the proceedings.
The trial court denied the defendants’ motion, holding that the complaint sufficiently alleged that the defendants occupied approximately 4,000 square meters of the land, and that the statutory provision (Commonwealth Act No. 538) cited for suspension was only applicable to ejectment cases, not a general action for recovery of possession.

On July 8, 1949, the defendants responded by filing their answer, which reiterated several special defenses previously raised in their motion to dismiss.
The defenses included an assertion that the defendants were possessors in good faith—taking possession with the plaintiff’s knowledge and consent. They argued that the plaintiff had allowed them to build houses on the land and prescribed a rental payment, and that the defendants had occupied the land without obstruction until a recent incident involving a neighboring Chinese proprietor signifying an intention to occupy the premises.
Additionally, the defendants instituted a counterclaim for the value of the improvements made on the land, totaling P56,500.

The court session on August 23, 1949, saw the plaintiff appearing with counsel, while all forty-nine defendants along with their counsel failed to appear.
Due to the absence of the defendants, the court proceeded ex parte with the plaintiff’s presentation of evidence.
On September 9, 1949, the trial court rendered a decision granting the relief sought in the complaint, except for the claim for damages, and dismissed the counterclaim presented by the defendants.

On September 14, 1949, the defendants filed a motion to set aside the decision and for a new trial. They contended that their failure to appear at trial was due to an inadvertence or mistake on the part of Dominador Villafuerte, the stenographer and filing clerk for their counsel, as evidenced by an attached affidavit.
The defendants also reiterated that they had valid defenses which had been set forth in their previous filings and which could have been proven if given the opportunity.
The plaintiff opposed this motion on the grounds that even if the case were reopened, the defenses on record could not alter the court’s decision.
On October 6, 1949, the trial court denied the defendants’ motion for a new trial.
Subsequently, on October 11, 1949, the defendants elevated the case to the Court of Appeals, after which it was certified to the Supreme Court on the basis that the appeal involved questions of law.
In the appeal, the defendants made four assignments of error focusing on:

The denial of the motion for a bill of particulars or dismissal.
The denial of the motion for suspension of the proceedings under Commonwealth Act No. 538.
The alleged abuse of discretion in proceeding with an ex parte trial in the absence of all defendants and their counsel.
The denial of the motion to set aside the decision and grant a new trial on the merits.

Whether the trial court erred in denying the defendants’ motion for a bill of particulars or dismissal, given that the complaint sufficiently alleged the extent of the defendants’ occupation (approximately 4,000 square meters).

Whether it was erroneous for the trial court to deny the defendants’ motion for suspending the proceedings by invoking Commonwealth Act No. 538, which provides for the suspension of ejectment actions but may not be applicable to an ordinary action for recovery of possession.

Whether the trial court abused its discretion by proceeding with the trial ex parte, in light of the defendants’ absence caused by alleged inadvertence or mistake by an employee of their counsel.
Whether the defendants were unjustly deprived of their substantial right to present evidence and be represented by counsel.

Whether the trial court erred in denying the defendants’ motion to set aside its decision and order a new trial on the merits, despite their claims of having valid defenses that, if proven, might have altered the outcome of the case.