Case Summary (G.R. No. 227457)
Factual Background
The respondent, Gabriel Dizon, filed a complaint for the Declaration of Nullity of the Deed of Absolute Sale before the RTC against Robert Dizon and the petitioners. This complaint was dismissed by the RTC due to forum shopping, as another similar case was already pending involving the same parties and subject matter. Following the final dismissal, the petitioners filed an ex-parte motion to set their defendants’ counterclaim for hearing. The RTC issued a Notice of Hearing scheduling the case for March 13, 2014. Petitioners filed their Judicial Affidavits on March 12, 2014, one day before the scheduled hearing. Respondent opposed the admission of these affidavits, asserting they were filed late pursuant to Section 2(a) of the Judicial Affidavit Rule, which requires Judicial Affidavits to be submitted at least five days prior to the scheduled hearing.
RTC’s Ruling on the Late Submission of Judicial Affidavits
The RTC admitted the late-filed Judicial Affidavits in its September 2, 2014 Order, reasoning that the Notice of Hearing constituted confirmation that the counterclaim would be heard on the specified date. The RTC emphasized that technical rules should yield to substantial justice and allowed the submission despite the late filing. Upon respondent’s motion for reconsideration, the RTC denied the motion but imposed a fine of P2,500.00, modifying its earlier order pursuant to Section 10(a) of the JAR, which permits late submission once under certain conditions.
Court of Appeals’ Decision
The CA reversed the RTC’s Orders, holding that the RTC gravely abused its discretion by admitting the belated Judicial Affidavits without proof of compliance with all conditions in Section 10(a) of the JAR. The CA acknowledged payment of the fine by the petitioners but found no valid reason presented for the delay and no evidence that respondent would not be unduly prejudiced. Thus, the CA annulled the RTC’s admission of the Judicial Affidavits. Petitioners’ motion for reconsideration before the CA was denied.
Issue
Whether the Court of Appeals erred in finding grave abuse of discretion on the part of the RTC for admitting the belatedly filed Judicial Affidavits of petitioners despite non-compliance with the specific conditions under Section 10(a) of the Judicial Affidavit Rule.
Legal Standards Under the Judicial Affidavit Rule (JAR)
Section 2(a) requires that judicial affidavits and documentary evidence be filed and served “not later than five days before pre-trial or preliminary conference or the scheduled hearing.” Section 10(a) stipulates that failure to submit judicial affidavits and exhibits on time amounts to waiver, but courts may allow late submission once if:
- The delay is for a valid reason,
- The late submission would not unduly prejudice the opposing party, and
- The defaulting party pays a fine between P1,000.00 and P5,000.00 at the court’s discretion.
Court’s Analysis on Compliance with JAR Conditions
The Court confirmed that the RTC has discretion under Section 10(a) of the JAR to allow late submissions once, provided all three conditions are met. It noted that petitioners paid the required fine, conceding compliance with the third condition. The principal issues were whether there was a valid reason for the delay and whether respondent was unduly prejudiced.
Petitioners explained that their counsel genuinely believed the Notice of Hearing was merely a notification and not the formal grant of the ex-parte motion setting the hearing, which was a genuine, good faith procedural mistake. The Court observed that the petitions were only four days late and filed before the hearing itself, indicating no deliberate defiance of the rules. Furthermore, the Notice of Hearing’s language did not expressly require the filing of Judicial Affidavits nor specify consequences for failure to comply, adding to the reasonable misunderstanding.
Assessment of Prejudice and Due Process Considerations
The Court found no undue prejudice to the respondent as the hearing on March 13, 2014, did not involve the actual presentation of evidence on the counterclaim. The trial proper on the merits occurred later, allowing the respondent to present rebuttal evidence. The admission of the Judicial Affidavits did not preclude the respondent’s right to be heard or render the trial unfair. Therefore, no substantial rights of the respondent were impaired.
The Court emphasized that the admission of affidavits does not guarantee success on the counterclaim, as the case would still be decided on the merits based on the evidence presented by both parties. The respondent indeed submitted rebuttal evidence, negating claims of prejudice.
Jurisprudential Principles and Judicial Discretion
The Cour
...continue readingCase Syllabus (G.R. No. 227457)
Background and Procedural History
- The case involves a petition for review on certiorari filed by petitioners Helen L. Say, Gilda L. Say, Henry L. Say, and Danny L. Say, assailing the May 13, 2016 Decision and August 24, 2016 Resolution of the Court of Appeals (CA).
- The CA had set aside the September 2, 2014 and April 1, 2015 Orders of the Regional Trial Court (RTC) of Koronadal City, Branch 24 in Civil Case No. 1973-24.
- The RTC orders admitted the belated submission of the Judicial Affidavits of petitioners despite non-compliance with Section 10(a) of the Judicial Affidavit Rule (JAR).
- The primary question is whether the RTC gravely abused its discretion in allowing the late filing of said Judicial Affidavits.
Facts of the Case
- Respondent Gabriel Dizon filed a complaint for Declaration of Nullity of the Deed of Absolute Sale against Robert Dizon and petitioners before the RTC docketed as Civil Case No. 1973-24.
- The RTC dismissed this case on November 23, 2011, due to forum shopping because respondent had filed a similar complaint, Civil Case No. 1263-25, involving the same subject matter.
- After dismissal became final, petitioners filed an Ex-Parte Motion for Leave of Court to Set Defendants' Counterclaim for Hearing.
- The parties were notified via a Notice of Hearing on November 25, 2013, that the hearing was set for March 13, 2014.
- Petitioners filed their Judicial Affidavits on March 12, 2014, one day before the hearing date.
- Respondent opposed the filing, claiming it was out of time under Section 2(a) of the JAR that requires submission at least five days before the hearing.
RTC’s Rulings
- On September 2, 2014, the RTC admitted petitioners’ Judicial Affidavits despite late filing, invoking the principle that technicalities must give way to substantial justice.
- The RTC considered the Notice of Hearing as confirmation that March 13, 2014, was the hearing of the counterclaim.
- Respondent’s motion for reconsideration was denied on April 1, 2015, but the RTC modified its earlier order by imposing a P2,500.00 fine on petitioners for late submission pursuant to Section 10(a) of the JAR.
- The RTC thus balanced technical irregularity with substantive justice by allowing late submission with a penalty.