GR 143794; (July, 2004) (Digest)
G.R. No. 143794 . July 13, 2004.
VIKING INDUSTRIAL CORPORATION, petitioner, vs. THE COURT OF APPEALS and JOSE L. LUISON, JR., respondents.
FACTS
Respondent Jose L. Luison, Jr. filed a petition for prohibition and declaratory relief against “Viking Trading Corporation” to contest the computation of his loan indebtedness secured by a real estate mortgage. The petitioner, the correct party Viking Industrial Corporation, refused to file an answer because it was improperly impleaded as “Viking Trading Corporation.” Consequently, the trial court declared petitioner in default, rendered a judgment by default in favor of Luison, and later fully executed the judgment. Petitioner subsequently filed a motion for new trial, arguing it was denied its day in court due to an “honest mistake” in the name used in the pleadings.
The Regional Trial Court initially granted the motion for new trial but was reversed by the Court of Appeals, which found no grave abuse of discretion in the default judgment. Petitioner elevated the case, insisting the misnomer deprived the court of jurisdiction and that its failure to answer was an honest mistake warranting a new trial.
ISSUE
Whether the Court of Appeals erred in affirming the denial of petitioner’s motion for new trial based on the ground of “honest mistake.”
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that a motion for new trial on the ground of “honest mistake” requires a showing that ordinary prudence could not have guarded against the error. Petitioner’s failure to file an answer was not due to an honest mistake but to a deliberate and obstinate refusal based on a technical misnomer, despite being fully aware of the action and its details.
The Court emphasized that litigation is not a “trial and error” proceeding. Jurisdiction was validly acquired over petitioner as summons and court processes were received by its agents at its correct address, and its president actively participated in the execution of the judgment. The prior finality of a related case affirmed the validity of the default judgment. Granting a new trial under these circumstances would set a dangerous precedent allowing parties to evade litigation through mere technicalities, contrary to the public interest in the finality of judgments. Petitioner’s obstinacy precludes relief.