GR 157219; (May, 2004) (Digest)
G.R. No. 157219; May 28, 2004
NATIVIDAD E. BAUTISTA, CLEMENTE E. BAUTISTA and SOCORRO L. ANGELES, petitioners, vs. THE HONORABLE COURT OF APPEALS, MANILA PAPERMILLS, INTERNATIONAL, INC., ADELFA PROPERTIES, INC. and SPOUSES RODOLFO JAVELLANA and NELLY JAVELLANA, respondents.
FACTS
Petitioners filed a complaint for quieting of title before the RTC of Imus, Cavite, alleging actual and uninterrupted possession of Lot 5753 and claiming that the reconstituted title in the name of respondents was spurious. After several delays, the case was set for trial. On May 2, 2002, petitioners filed an Urgent Motion for Postponement on the ground that their assigned lawyer was abroad. The trial court denied the motion and declared petitioners to have waived the presentation of their evidence. Their motion for reconsideration was likewise denied.
Petitioners elevated the matter via a special civil action for certiorari to the Court of Appeals, arguing that the trial court’s denial of their motion, contrasted with its prior grants of respondents’ requests for extensions and postponements, demonstrated partiality and violated their right to due process. The appellate court dismissed the petition, prompting this petition for review.
ISSUE
Whether the Court of Appeals erred in ruling that the trial court did not commit grave abuse of discretion in denying petitioners’ motion for postponement and declaring a waiver of their right to present evidence, thereby allegedly violating their right to due process.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is clear: the grant or denial of a motion for postponement is discretionary upon the trial court. An appellate court will not interfere absent a clear showing of grave abuse of discretion, which implies a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction. Here, the trial court’s denial was justified as the motion was filed on the very day of the scheduled hearing, following previous grants of postponement to petitioners. This action was aimed at preventing further delay, not manifesting bias.
The Court distinguished between extensions to file pleadings, which are less disruptive, and postponements of trial dates, which waste court resources and the time of prepared witnesses. Due process is not violated when a party, having been afforded the opportunity to be heard, fails to avail of it; the right is deemed waived. The trial court’s duty to expedite proceedings outweighs a party’s dilatory tactics. Therefore, no grave abuse of discretion attended the trial court’s orders, and petitioners were not deprived of due process.