GR 207266; (June, 2014) (Digest)
G.R. No. 207266, June 25, 2014
HEIRS OF PACIANO YABAO, Represented by REMEDIOS CHAN, Petitioners, vs. PAZ LENTEJAS VAN DER KOLK, Respondent.
FACTS
Petitioners, the Heirs of Paciano Yabao, filed a complaint for ownership and possession of a parcel of land (Lot 2473) in Calbayog City against respondent Paz Lentejas Van der Kolk before the Municipal Trial Court in Cities (MTCC). They alleged they were the absolute co-owners of the lot. Respondent, through her attorney-in-fact, was served with summons while she was in the Netherlands. She filed a Motion to Dismiss, which the MTCC denied, directing her to file an Answer. After changes in counsel and delays, respondent filed an Answer belatedly. The MTCC declared respondent in default for failure to file an Answer within the prescribed period and rendered a Decision based solely on the allegations of the complaint, declaring petitioners as lawful co-owners and possessors and ordering respondent to vacate and pay attorney’s fees. Respondent appealed to the Regional Trial Court (RTC). The RTC dismissed the appeal for respondent’s failure to file her appeal memorandum within the reglementary period. Respondent then filed a petition for review with the Court of Appeals (CA). The CA granted the petition, reversing the MTCC and RTC decisions. It held that the MTCC erred in granting relief based solely on the complaint’s allegations without requiring petitioners to present ex parte evidence after the default declaration. The CA dismissed the complaint for failure to prove entitlement by the required quantum of evidence, without prejudice to refiling. Petitioners sought review by the Supreme Court.
ISSUE
Whether the Court of Appeals erred in reversing the decisions of the lower courts and dismissing the complaint for petitioners’ failure to prove their case by the required quantum of evidence.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision. The Court held that a judgment by default does not automatically result in a favorable judgment for the plaintiff. The plaintiff must still present evidence to prove the allegations in the complaint. The court cannot rely solely on the allegations in the complaint and must require the plaintiff to submit evidence. The MTCC erred in rendering judgment based merely on the allegations in the complaint after declaring respondent in default. The CA correctly ruled that petitioners failed to prove their entitlement to the property by the required quantum of evidence. The Court emphasized that default judgments are frowned upon, and cases should be decided on the merits whenever possible after giving parties full opportunity to be heard. The dismissal by the CA was without prejudice to the refiling of another case.