Title
San Miguel Brewery, Inc. vs. Legarda
Case
G.R. No. 25072
Decision Date
Dec 18, 1925
Legarda is entitled to have his bill of exceptions signed by the court, recognizing the distinction between motions for a new trial on formal grounds and those based on newly discovered evidence.
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Case Summary (G.R. No. 25072)

Motion for New Trial: Distinction and Procedure

  • A litigant who has lost a case may file two separate motions for a new trial: one based on newly discovered evidence and another on formal grounds.
  • The first motion does not need to be combined with the second; they can be submitted sequentially.
  • The court must address the motion for newly discovered evidence before the litigant submits the formal motion for a new trial.

Suspension of Time for Filing Subsequent Motions

  • The time period for filing a second motion for a new trial is suspended while the first motion is under advisement by the judge.
  • Specifically, the duration during which the judge considers the first motion must be deducted from the statutory time allowed for the second motion.
  • This ensures that the litigant is not unfairly penalized by the time taken for the court to deliberate on the first motion.

Case Background and Procedural History

  • The San Miguel Brewery filed a civil action against Domingo Legarda to recover the value of twenty ammonia tubes, resulting in a judgment in favor of the Brewery.
  • After the judgment was notified to Legarda, he discovered receipts indicating he had delivered the tubes, prompting him to file a motion for a new trial based on this newly discovered evidence.
  • The initial motion was denied, and a subsequent formal motion for a new trial was filed, which was also denied.

Court's Rationale and Decision

  • The court determined that the petitioner (Legarda) was entitled to have his bill of exceptions signed, as the motions were based on different grounds.
  • The judge's belief that only one motion for a new trial could be filed was incorrect; the law allows for separate motions based on distinct grounds.
  • The court concluded that the time for filing the second motion was properly calculated, taking into account the suspension of t...continue reading

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