G.R. No. 198196, July 17, 2017
Spouses Loreto and Milagros Sibay and Spouses Ruel and Olga Elas, Petitioners vs. Spouses Bienvenido and Juanita Bermudez, Respondents

FACTS

The petitioners, Spouses Loreto and Milagros Sibay, were the registered owners of a parcel of land mortgaged to Land Bank of the Philippines (LBP). After foreclosure, LBP sold the property to Nemesia Bermudez, whose assignees, the respondent Spouses Bermudez, became caretakers. The Spouses Sibay filed a complaint for annulment of the loan contract. During the proceedings, Loreto Sibay failed to attend the March 18, 2008 hearing due to arthritis. The trial court reset the hearing and directed him to submit a medical certificate, warning of reimbursement for unjustified postponement.
Subsequently, the Spouses Sibay’s counsel filed a motion to postpone the July 29, 2008 hearing due to a conflicting schedule in another court. The trial court denied this motion. In its July 29, 2008 Order, the court fined the Spouses Sibay a total of Php10,000.00—Php5,000.00 for reimbursement and Php5,000.00 for the earlier unexcused absence—later reduced to Php5,000.00. The Spouses Sibay filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion, but the CA denied it. Hence, this petition.

ISSUE

Whether the Court of Appeals correctly found that the trial court committed no grave abuse of discretion in denying the motion for postponement and imposing a fine.

RULING

The Supreme Court denied the petition, affirming the CA’s decision. The Court emphasized that a petition for review under Rule 45 is limited to questions of law, not re-evaluating factual findings. The core issue was whether the trial court gravely abused its discretion. The grant or denial of a motion for postponement is addressed to the sound discretion of the trial court, predicated on serving the ends of justice and fairness. A motion for postponement is a privilege, not a right, and a movant cannot assume its grant.
The Court found no grave abuse of discretion. For the March 18 absence, Loreto Sibay’s claim of severe arthritis was unsupported by a timely submitted medical certificate as ordered by the court. For the July 29 absence, counsel’s conflict with another hearing schedule did not constitute a compelling reason warranting postponement, as courts are not obligated to accommodate counsel’s calendar conflicts. The imposition of a nominal fine was within the court’s disciplinary power to prevent undue delays and ensure orderly proceedings. Procedural rules are not mere technicalities; their observance is essential to the prompt administration of justice. The trial court’s actions were a proper exercise of its authority to control its calendar and prevent dilatory tactics.