Case Summary (G.R. No. 55488)
Applicable Law
The resolution of this case is primarily based on the 1987 Philippine Constitution and relevant provisions of the Civil Code concerning succession and partition. Additionally, the Rules of Court regarding motions for new trial and grounds for appeal are crucial to this case's legal analysis.
Procedural History
The private respondents commenced the action on August 2, 1979, resulting in multiple hearings that were repeatedly postponed at the petitioners' behest. The trial court issued a warning regarding failure to appear, and following a string of cancellations, the case was submitted for decision on September 7, 1979, due to the petitioners’ counsel's absence. The petitioners filed a motion for reconsideration of this order on September 26, 1979, claiming an agreement for a reschedule, which was denied by the trial court on November 9, 1979. Ultimately, the court rendered a decision favoring the private respondents on April 22, 1980, declaring their rights to the property's inheritance.
Motion for New Trial and Appeal Timeline
Subsequent to the decision, the private respondents sought execution of the judgment while the petitioners delayed filing their motion for new trial until June 2, 1980, which was motioned later questioned as pro forma by the private respondents. The petitioners filed a notice of appeal on June 13, 1980, after the decision was received on May 13, 1980. However, they submitted the record on appeal only on June 17, 1980, prompting the private respondents to move for the appeal's dismissal, arguing it was filed beyond the allowable period.
Court's Reasoning on "Pro Forma" Motion
The lower court ruled that the petitioners' motion for new trial was pro forma, which means it was deemed merely formal and insufficient to suspend the period for appeal. The basis of their new trial motion—specifically referencing counsel’s honest mistake or excusable negligence—was previously addressed in their motion for reconsideration, thus rendering the current new trial motion as repetitive and unsubstantiated. The court highlighted that for a motion for new trial to be substantial based on newly discovered evidence, clear evidence and circumstances must be detailed, which the petitioners failed to provide.
New Evidence Claims and Court's Disbelief
The petitioners claimed newly discovered evidence pertaining to the reappearance of Moya Amadya Dapin, which ostensibly would alter the trial's outcome. However, the court identified significant inconsistencies in this claim, notably questioning the credibility of the circumstances sur
...continue readingCase Syllabus (G.R. No. 55488)
Case Background
- The case revolves around a partition action with a prayer for damages filed by the private respondents, heirs of Monica Pocong, against the petitioners, Marciana Dapin and Adriano Malmis.
- The private respondents allege unlawful deprivation of inheritance concerning a 23-hectare agricultural land originally belonging to Felix Dapin, Monica Pocong's second husband and Marciana Dapin's father.
- Key dates include:
- August 2, 1979: Filing of the partition case.
- 1960: Death of Felix Dapin.
- 1975: Death of Monica Pocong.
- 1973: Marciana Dapin executed an affidavit of adjudication of the property to herself.
Procedural History
- The trial court scheduled hearings on several occasions, which were postponed due to the petitioners' requests.
- On September 7, 1979, the petitioners' counsel failed to appear, leading the court to consider the case submitted for decision.
- The petitioners filed a motion for reconsideration on September 26, 1979, arguing that there was an agreement to postpone the hearing, but it was denied on November 9, 1979.
- The trial court rendered a decision on April 22, 1980, granting partition to the private respondents and awarding damages.
Motion for Execution and Appeals
- Following the decision, the private respondents filed a motion for execution pending appeal on April 24, 1980.
- The petition