Case Summary (G.R. No. 202597)
Procedural Background
On February 14, 2011, the petitioners initiated a petition for annulment of judgment in the Court of Appeals to challenge the RTC's decision in Special Proceedings Case No. 4577. Following the submission of responsive pleadings to their petition, the Court of Appeals set a preliminary conference for October 4, 2011, requiring both parties to file pre-trial briefs. Instead of complying, the petitioners submitted a Motion for Summary Judgment and a Motion to Hold Pre-Trial in Abeyance.
Non-Appearance and Dismissal
During the scheduled preliminary conference, neither the petitioners nor their counsel appeared. Consequently, on November 16, 2011, the Court of Appeals dismissed the petition for annulment based on the petitioners’ non-compliance with the Rules of Court. Specifically, the Court cited Sections 4 through 6 of Rule 18 of the Rules of Court, which outlines the obligations of the parties to appear at pre-trial and to file pre-trial briefs, stating that non-appearance could lead to dismissal of the action.
Motion for Reconsideration
Following the dismissal, the petitioners filed a Motion for Reconsideration; however, this motion was ultimately denied on January 9, 2012, for being untimely. The petitioners subsequently filed another Motion for Reconsideration challenging the January 9, 2012 resolution, which was denied by the Court of Appeals on June 20, 2012. Dissatisfied with these outcomes, they escalated the matter to the Supreme Court through a petition for review on certiorari.
Court's Ruling on the Petition
The Supreme Court denied the petition for review, primarily for lack of merit. One key aspect emphasized by the Court was that any motions filed with the Court of Appeals are considered filed only upon actual receipt. The petitioners' Motion for Reconsideration was not filed within the 15-day window established under Section 1, Rule 52 of the Rules of Court.
Analysis of Summary Judgment and Pre-Trial
The Court also addressed the petitioners' argument regarding the precedence of their Motion for Summary Judgment over the pre-trial. While acknowledging that summary judgment motions could be filed before pre-trial, the Court clarified that their resolution prior to the pre-trial was not mandatory. The Court reiterated the importance of adhering to procedural rul
...continue readingCase Syllabus (G.R. No. 202597)
Case Background
- This case involves a petition for annulment of judgment filed by the petitioners, Spouses Sergio C. Pascual and Emma Servillion Pascual, against several respondents including First Consolidated Rural Bank (Bohol), Robinsons Land Corporation, and Atty. Antonio P. Espinosa.
- The petitioners aimed to nullify a decision rendered by the Regional Trial Court (RTC) in Butuan City, which ordered the cancellation of their notice of lis pendens recorded in Transfer Certificate of Title No. RT-42190.
Procedural History
- The petitioners filed their annulment petition on February 14, 2011, which prompted the Court of Appeals (CA) to schedule a preliminary conference on October 4, 2011.
- Instead of submitting the required pre-trial briefs, the petitioners filed a Motion for Summary Judgment and a Motion to Hold Pre-Trial in Abeyance.
- The petitioners and their legal counsel failed to attend the preliminary conference, resulting in the CA's resolution on November 16, 2011, which dismissed the annulment petition.
Court of Appeals Findings
- The CA noted that the petitioners' non-appearance at the pre-trial conference was unjustifiable, as outlined in Sections 4 to 6 of Rule 18 of the Rules of Court.
- The court emphasized that failure to appear or to file a pr