Title
Amante vs. Sunga
Case
G.R. No. L-40491
Decision Date
May 28, 1975
Petitioner sought extension to file answer, declared in default despite filing; Supreme Court ruled ex parte motion valid, default unjustified, remanded case.
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Case Summary (G.R. No. L-40491)

Motion for Extension of Time

  • Petitioner filed a written motion for an extension of time to file a responsive pleading, addressed to the clerk of court.
  • The motion was granted by the court on December 6, 1974.
  • Subsequently, a motion for a bill of particulars was filed by the petitioner.
  • Before compliance with the bill of particulars, the respondent corporation filed a motion to set aside the December 6 order, citing a defective notice.

Court's Default Order

  • The respondent court set aside its December 6 order on February 14, 1975, declaring the petitioner in default.
  • The court authorized the clerk of court to receive evidence from the plaintiff.
  • This action prompted the petitioner to question the validity of the February 14 order.

Supreme Court's Ruling on Ex Parte Motions

  • The Supreme Court ruled in favor of the petitioner, stating that a motion for extension of time to file an answer can be heard and granted ex parte.
  • The court emphasized that the respondent corporation was not deprived of any substantial rights due to the alleged defect in notice.
  • The default order and the denial of the motion for reconsideration were set aside.

Nature of Ex Parte Motions

  • A motion for extension of time is not a litigated motion requiring notice to the adverse party.
  • Ex parte motions are permissible in procedural matters and emergencies, allowing for timely relief without delay.
  • The court has the discretion to permit the submission of an answer even after the time fixed by the rules.

Impact of Motion for Bill of Particulars

  • The pendency of a motion for a bill of particulars interrupts the period for filing a responsive pleading.
  • The moving party is entitled to the same time to serve their answer as they had at the time of serving the motion.
  • The petitioner’s withdrawal of the bill of particulars did not negate the filing of his answer on the same day.

Examination of Default Orders

  • Default judgments are not based on the merits and can lead to significant injustice for the defendant.
  • The court must carefully examine the circumstances surrounding the issuan...continue reading

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