GR 57395; (April, 1989) (Digest)
G.R. No. L-57395. April 17, 1989.
ALFREDO DE GUZMAN, petitioner, vs. HON. JESUS M. ELBINIAS, in his capacity as Presiding Judge, CFI-Bulacan of Branch V, Sta. Maria and LUZ C. ROXAS, AMALIA CORREA-CALALANG and FRANCISCO CALALANG, respondents.
FACTS
The case originated from a dispute over a 5,000-square-meter agricultural land in Bulacan. Petitioner Alfredo de Guzman claimed to be a tenant, having taken over the land from his father-in-law, the original tenant, in 1968. Private respondents, the landowners, sought to recover possession, denying the existence of a tenancy relationship. After administrative proceedings at the Department of Agrarian Reform yielded conflicting reports, private respondents filed a civil action for recovery of possession (Civil Case No. SM-705) before the respondent Court of First Instance. The procedural history was protracted, marked by multiple postponements, predominantly at the instance of the private respondents over several years, which were routinely granted by the respondent judge. After the private respondents finally rested their case, the hearing was set for the petitioner to present his evidence.
ISSUE
Whether the respondent judge committed a grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petitioner’s motion for postponement of the hearing for the presentation of his evidence and in subsequently declaring the case submitted for decision without such evidence.
RULING
Yes. The Supreme Court granted the petition, nullifying the respondent judge’s order. The legal logic centers on the proper exercise of judicial discretion and the paramount importance of due process. While the grant or denial of a motion for postponement is discretionary, such discretion must be exercised judiciously and not arbitrarily. The Court emphasized that the discretion “should always be predicated on the consideration that more than the mere convenience of the courts or of the parties in the case, the ends of justice and fairness would be served thereby.”
The Court found the denial in this instance to be a grave abuse of that discretion. The petitioner’s counsel received notice of the hearing only two days prior, had a conflicting intransferable criminal case scheduled on the same date, and could not contact his client who resided a significant distance away. These constituted valid reasons for a postponement, especially considering that this was the first setting for the petitioner to present his crucial evidence. The respondent judge’s rationale—citing the petitioner’s alleged previous numerous postponements—was contradicted by the record, which showed the delays were overwhelmingly caused by the private respondents. To declare the case submitted without allowing the petitioner to present his evidence violated his fundamental right to due process and his day in court. The demand for speedy disposition must be balanced with the imperative of affording every party a full opportunity to be heard. The order was set aside, and the petitioner was allowed to adduce his evidence.