Title
Guinea vs. Vda. de Ramonal
Case
G.R. No. L-38659
Decision Date
Feb 20, 1975
A dispute over Lot No. 2059 in Cagayan de Oro erupted between petitioners and respondent Matilde S. Vda. de Ramonal. Petitioners claimed possession since birth, except wartime, but admitted absence 1940-1966. Judge rejected cumulative testimony, terminated evidence presentation due to counsel’s tardiness, and dismissed certiorari petition, upheld by Supreme Court. Petitioners’ dilatory tactics and inconsistent claims undermined case credibility.
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Case Summary (G.R. No. L-38659)

Nature of the Petition

This special civil action for certiorari was brought by the petitioners to annul specific orders issued by Judge Bernardo Teves on June 28, 1973, January 14, and February 22, 1974, in relation to Civil Case No. 2766. The petitioners alleged that these orders were made with grave abuse of discretion, equating to a lack or excess of jurisdiction.

Factual Background

The underlying case, Civil Case No. 2766, involves a complaint by the petitioners asserting that they had possessed the disputed lot "since their birth" up to February 1966, with interruptions only during World War II. During the trial, they presented seven witnesses to corroborate this claim. However, an eighth witness, Isabelo Ello, was denied the opportunity to testify by the respondent Judge based on a specific admission in the petitioners’ complaint, which indicated a lack of possession during the stated period.

Decisions of the Respondent Judge

The respondent Judge's first order on June 28, 1973, rejected Isabelo Ello’s testimony, affirming that it was in conflict with the established claim in paragraph 9 of the complaint. Subsequently, on January 14, 1974, the Judge denied a motion for reconsideration filed by the petitioners. On February 22, 1974, after the petitioners' counsel arrived late for a scheduled hearing, the Judge terminated the presentation of the petitioners' evidence and moved to allow the defendant, Mrs. Ramonal, to present her case.

Response to the Petitioners' Argument

The Court concluded that the trial court acted within its discretion by not permitting the additional testimony of Isabelo Ello, given that the anticipated testimony was merely cumulative and did not substantiate a new claim not already covered by the seven previous witnesses. The trial court has the authority to limit testimony if prior evidence is deemed sufficiently persuasive. Furthermore, allowing Ello's testimony would contradict the plaintiffs' own admission regarding possession.

Findings on the February 22, 1974 Hearing

On the hearing date, the petitioners were found to have displayed a lack of candor regarding the circumstances that transpired. The Judge allowed a brief recess when the petitioners' counsel was late, but upon his arrival, the counsel's request for reconsideration was promptly denied. The ruli

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