Title
Simon vs. Castro
Case
G.R. No. 2699
Decision Date
Jul 31, 1906
Claudia and Irene Castro sued Francisca Simon, who filed a demurrer but failed to answer. Judgment was rendered against her; she sought relief under Section 513, claiming default. The Supreme Court denied relief, ruling her judgment wasn’t a default as she had appeared and filed a demurrer.

Case Summary (G.R. No. 2699)

Facts of the Case

Claudia Castro and Irene Castro initiated a legal proceeding against Francisca Simon and her co-defendant, Jose de Castro. The summons was duly served to Francisca Simon on February 10, 1904. In compliance with legal requirements, she entered an appearance and filed a demurrer to the complaint within the prescribed timeline. This demurrer, however, was overruled. Following the overruling, a period was allotted for her to file an answer, which she ultimately failed to do. As a consequence, a judgment was issued against her on April 3, 1905, and she was notified of this on April 4, 1905.

Legal Procedure and Relief Sought

On May 18, 1905, within sixty days from her notification of the judgment, Francisca Simon filed a petition in the Supreme Court, seeking relief under Section 513 of the Code of Civil Procedure. This provision allows for the setting aside of judgments rendered in default due to factors such as fraud, accident, mistake, or excusable negligence when there is no adequate remedy left within the rendering court.

Previous Case Reference

The court cited the case of Blanco vs. Guerra to illustrate the application of Section 513. In that instance, defendants who had appeared and answered were unable to attend the trial due to the sudden death of their attorney. Their petition for relief was denied on the grounds that since they had previously participated in the proceedings, the situation did not warrant the application of Section 513.

Court's Analysis

In analyzing the current case, the Supreme Court recognized that Francisca Simon had indeed entered her appearance and presented a demurrer. Although she was entitled to respond to the complaint, she was not compelled to relinquish her demurrer. The court concluded that the judgment

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