A.M. No. P-18-3843 [Formerly OCA IPI No. 16-4612-P - Concerned Citizens vs. Ruth Tanglao Suareza Holguin, Utility Worker 1, Office of the Clerk of Court, Regional Trial Court, Angeles City, Pampanga

Resurreccion Vda. de Sta. Ana (plaintiff/respondent) initiated a suit against Rodolfo Rivera (defendant/petitioner).
Rivera failed to answer the complaint, resulting in a default declaration on December 1, 1962, by the Court of First Instance of Manila in Case No. 51726.

After receiving the plaintiff’s evidence (in Rivera’s absence), the court rendered judgment on January 7, 1963.

Judgment directed Rivera to pay P5,000.00 with interest at 12% per annum from January 1, 1959, plus P500.00 for attorney’s fees.

Rivera filed, on July 3, 1963 (within the six-month period as prescribed by Rule 38, Section 3), a sworn petition for relief.

He claimed that he was unaware of the judgment until May 22, 1963, when a writ of garnishment was served on his employer.
Rivera attributed his failure to answer the complaint to "lack of legal advice," alleging excusable negligence.
He further asserted that he had made partial payments evidenced by receipts, and that the promissory note was executed under usurious conditions.

On July 6, 1963, the court ordered Rivera to serve a copy of the motion on the plaintiff and directed the latter to answer.
Later, upon the motion and filing of a P500.00 bond, the court enjoined execution of the original judgment pending the relief petition's resolution.
At the subsequent hearing on August 22, 1963, plaintiff’s counsel admitted that partial payments had been made, noting the willingness to adjust the amounts by deducting payments made.

On August 24, 1963, after the court had denied the petition for relief on the ground of insufficient excusable negligence, Rivera moved to amend his petition.

The amendment was intended to reflect evidence regarding partial payments and to claim fraud by the plaintiff for demanding full payment without deduction.

The trial court denied both the defendant’s motion for relief and the motion to amend the petition.
Rivera subsequently appealed the decision to the Supreme Court.

Whether the defendant's petition for relief, despite its technical deficiencies, should be granted based on the overwhelming evidence of injustice.

Whether the admission by the plaintiff’s counsel regarding partial payments and the willingness to adjust the claim should affect the enforcement of the default judgment.

Whether the plaintiff's conduct, which involved concealing the fact that part of the claim was already satisfied, constitutes an imposition and fraud upon the court, thereby justifying relief.