GR 148273; (April, 2006) (Digest)
G.R. No. 148273 ; April 19, 2006
MILAGROS SIMON and LIBORIO BALATICO, Petitioners, vs. GUIA W. CANLAS, Respondent.
FACTS
Edgar H. Canlas filed a complaint for judicial foreclosure of a real estate mortgage against petitioners Milagros Simon and Liborio Balatico. He alleged that Milagros obtained a loan from him secured by a mortgage over her paraphernal property. Upon Edgar’s death, his wife, respondent Guia W. Canlas, was substituted as plaintiff. Petitioners denied the transaction, claiming they never received the loan proceeds and were duped by third parties. During pre-trial, the parties stipulated only on the execution of the mortgage deed.
During trial, petitioners’ counsel repeatedly sought postponements and eventually withdrew. Their new counsel also filed motions to reset. The trial court, after granting several resets and issuing final warnings, denied a further motion due to respondent’s vigorous objection and petitioners’ pattern of delay. The court deemed petitioners to have waived their right to present evidence and considered the case submitted for decision.
ISSUE
Whether the trial court gravely abused its discretion in denying petitioners’ motion for postponement and in declaring that they waived their right to present evidence.
RULING
No, the trial court did not commit grave abuse of discretion. The Supreme Court affirmed the decisions of the lower courts. The right to present evidence is not absolute and must be balanced with the orderly administration of justice. The trial court has the inherent power to control its proceedings to prevent undue delays.
The legal logic is grounded on procedural rules and judicial discretion. The record showed a clear pattern of delay attributable to petitioners and their counsel through successive postponements and non-appearances. The trial court acted with liberality initially but was justified in putting an end to the protracted proceedings after issuing multiple warnings. Denying the final motion for postponement was a reasonable exercise of discretion to prevent further prejudice to the respondent and to expedite the case. Consequently, petitioners were correctly deemed to have waived their right to present further evidence. The waiver, however, did not automatically result in a judgment against them. The respondent still had the burden to prove her case by preponderance of evidence, which the courts found she had satisfactorily discharged based on the evidence she presented, including the stipulated mortgage deed.