G.R. No. L-10010; August 1, 1916
CHU JAN, plaintiff-appellee, vs. LUCIO BERNAS, defendant-appellant.

FACTS:
On June 26, 1913, a cockfight was held in Tabaco, Albay, between cocks owned by the plaintiff, Chu Jan, and the defendant, Lucio Bernas. Each bet P160. The cockpit referee declared the defendant’s cock the winner. The plaintiff filed a suit in the justice of the peace court, contesting the result and seeking to have his own rooster declared the winner. That court ruled the bout was a draw. The defendant appealed to the Court of First Instance. In his complaint for the appeal, the plaintiff prayed for judgment ordering the defendant to comply with cockpit rules, to pay the P160 wager, and for the release of the total bet of P320 held by the cockpit owner. The Court of First Instance dismissed the appeal, citing that it always dismissed such cases, was unfamiliar with cockpit rules and the duties of referees, did not know where to find the applicable law, and knew of no law governing the rights of parties in cockfighting disputes. The plaintiff moved for the release of the deposited money, which the court granted. The defendant appealed both the judgment of dismissal and the order for release.

ISSUE:
Whether the trial court may dismiss a case solely on the grounds of its ignorance of the applicable law or rules governing the subject matter of the dispute.

RULING:
No. The Supreme Court reversed the judgment and order of the Court of First Instance. The Court held that a judge’s ignorance of the applicable law, lack of knowledge of the rules pertinent to the case, or not knowing where to find the law are not valid reasons for dismissing proceedings without deciding the issues on their merits. The Court emphasized that, pursuant to Article 6, paragraph 2 of the Civil Code, if no specific law is exactly applicable, the customs of the place shall be observed, and in the absence thereof, the general principles of law. The case was remanded to the trial court for proper trial and judgment in accordance with law. No costs were awarded.