G.R. No. L-22736 July 9, 1971
PEOPLE’S HOMESITE & HOUSING CORPORATION, plaintiff-appellee, vs. CORAZON MOBO, ET AL., defendants, CORAZON MOBO, defendant-appellant.

FACTS

The People’s Homesite & Housing Corporation (PHHC) filed an action to recover possession of a subdivision lot registered in its name from defendant Corazon Mobo and others. PHHC alleged ownership based on its Transfer Certificate of Title and sought the defendants’ ejectment, removal of their constructions, and payment of monthly rentals. Mobo admitted PHHC’s ownership but asserted special defenses and a counterclaim. She claimed she was a long-time actual occupant who had applied to purchase the lot and, in good faith, introduced improvements. She argued that PHHC failed to notify her of its award of the lot to another applicant, Felipe Gahol, and that this award was irregular as it disregarded PHHC’s policy of giving priority to actual occupants.
The case was set for trial on November 27, 1963. Mobo’s counsel, Atty. Ben Hur Z. Mobo, received notice on November 22 and filed a motion for postponement the next day, citing a conflicting hearing in a Manila criminal case. The motion was not set for a specific hearing. When only PHHC appeared on November 27, the trial court allowed it to present evidence ex parte. Mobo’s counsel later moved for reconsideration and a new trial, but the court rendered a decision in favor of PHHC on December 11, 1963, based on the ex parte evidence. Mobo subsequently filed a motion to set aside the decision, which was not under oath nor supported by affidavits of merit, and it was denied.

ISSUE

Whether the trial court committed a reversible error, amounting to a deprivation of due process, in denying Mobo’s motions for postponement, for reconsideration, and to set aside the decision.

RULING

The Supreme Court affirmed the trial court’s decision, holding no reversible error was committed. The Court ruled that the grant or denial of a motion for postponement is discretionary with the trial judge. Absent a clear showing of grave abuse of that discretion, the higher court will not interfere. More critically, even if a denial were an abuse, a decision will not be reopened unless the aggrieved party demonstrates a meritorious defense.
The Court found Mobo failed to show a meritorious case. She expressly admitted PHHC’s ownership of the land and her occupation without any contractual authority from the owner. Her claimed priority right, based on her status as an actual occupant and applicant, was deemed an insufficient legal defense against a recovery action filed by the registered owner. Since she presented no valid legal right to occupy the property against the will of the titled owner, the trial court’s denial of her motions and its judgment for PHHC were proper. No deprivation of due process occurred, as the opportunity to be heard was provided but forfeited due to her counsel’s failure to properly secure a postponement and her subsequent failure to substantiate a valid defense.