G.R. No. 192320 April 4, 2016
BENJAMIN L. VERGARA, JONA M. SARVIDA and JOSEPHINE P. SABALLA, Petitioners, vs. ATTY. EUSEBIO I. OTADOY, JR., Respondent.

FACTS

This case originated from a civil action for damages filed by petitioners against respondent Atty. Eusebio I. Otadoy, Jr., and others, alleging unjust detention from a prior habeas corpus case. After procedural defaults, the RTC set a pre-trial conference for March 12, 2007. Atty. Otadoy filed an urgent motion to postpone, claiming a prior commitment to deliver a lecture at a religious conference in Zamboanga from March 11-14, 2007. Without awaiting the court’s ruling, he attended the event. During the pre-trial, petitioners’ counsel opposed the motion for being late and for Atty. Otadoy’s failure to file a pre-trial brief, moving instead to present evidence ex parte under Rule 18, Section 5 of the Rules of Court. The RTC granted the motion, adopted petitioners’ previously presented evidence, and considered the case submitted for resolution.
The Court of Appeals reversed the RTC, holding that while Atty. Otadoy was at fault for presuming his motion would be granted, the RTC should have prioritized giving him a full opportunity to litigate over technicalities, as this was his sole request for postponement. The CA deemed the RTC’s denial a grave abuse of discretion.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in denying Atty. Otadoy’s motion to postpone the pre-trial conference.

RULING

The Supreme Court granted the petition, reversing the CA and reinstating the RTC’s order. The Court held that the RTC did not commit grave abuse of discretion. A motion for postponement is a privilege, not a right, and the movant cannot assume its automatic grant. Under Rule 18, pre-trial is mandatory to ensure the speedy disposition of cases. A party’s non-appearance permits the court to allow the present party to present evidence ex parte. In evaluating a postponement request, the court must consider the reason given and the merits of the movant’s case.
Here, Atty. Otadoy failed to show a valid cause. His reason—a prior speaking engagement—was a voluntary commitment that did not constitute a compelling or unavoidable conflict excusing his mandatory appearance. He also failed to file a pre-trial brief and presumptuously absented himself without court approval. The RTC’s denial had legal basis under procedural rules aimed at preventing delay. The CA erred in overriding this discretion, as no grave abuse—characterized by caprice or whimsicality—was present. The RTC’s order was a proper exercise of judicial authority to enforce procedural discipline.