G.R. No. 48859 ; November 8, 1942
EMILIANO J. VALDEZ, petitioner, vs. FERNANDO JUGO, Judge of First Instance of Manila, ET AL., respondents.

FACTS

Petitioner Emiliano J. Valdez filed a motion for new trial on November 22, 1941, and scheduled its hearing for December 20, 1941—almost one month later. He explained orally that he needed this time to study the transcript of witness testimony to find reasons supporting the grounds in his motion. When asked why he did not inquire about the result of his motion after the Manila courts reopened, he stated he was not interested in speeding up the proceedings because he was the defeated party. The motion for new trial failed to specify in detail the reasons supporting its grounds as required by the rules.

ISSUE

Whether the petitioner’s motion for new trial interrupted the period for appeal, given its failure to comply with the specificity requirements under the Rules of Court.

RULING

No. The motion for new trial did not and could not interrupt the period for appeal. Under Rule 37, Section 2, third paragraph, a motion for new trial must “point out specifically the findings or conclusions of the judgment which are not supported by the evidence or which are contrary to law, making express reference to the testimonial or documentary evidence or to the provisions of law alleged to be contrary to such findings or conclusions.” The petitioner’s motion failed to meet this requirement and was therefore treated as a pro-forma motion intended merely to delay proceedings, which is offensive to the new rules and shall be stricken out.
The Court further noted that the petitioner’s actions demonstrated a deliberate attempt to delay proceedings for his own convenience: he filed the motion without knowing if the grounds were valid, scheduled a delayed hearing to gain time for study, and admitted he was not interested in expediting the case because he was the defeated party. Given this attitude, the Court refused to grant equitable relief.