G.R. No. L-14724; October 26, 1960
VICTORINO MARIBOJOC, petitioner, vs. HON. PASTOR L. DE GUZMAN, ETC., ET AL., respondents.

FACTS

Dolores Kapungan, as administratrix and part-owner of a 67-hectare land in Labangon, Cebu, filed a petition on May 9, 1958, before the Court of Agrarian Relations in Cebu City. She sought to eject her tenant, Victorino Maribojoc, for allegedly failing to pay her share of the 1957 crop and requested damages. Maribojoc was served with summons but failed to answer, leading the court to declare him in default upon Kapungan’s motion. Kapungan then presented evidence before a commissioner, and the court found that Maribojoc violated paragraphs (b) and (c), Section 50 of Republic Act 1199 by not delivering the landholder’s share. The court rendered judgment allowing Kapungan to eject Maribojoc and replace him with another tenant, but no damages were awarded due to insufficient evidence. On July 16, 1958, Maribojoc filed a motion for reconsideration, alleging that the default order was obtained through fraud, deceit, and misrepresentation, and that the decision was null and void because he was denied his day in court. The motion was denied on October 1, 1958. Maribojoc gave notice of his intent to appeal on October 7, 1958, and filed the present petition for review on October 20, 1958.

ISSUE

Whether the agrarian court abused its discretion in denying Maribojoc’s motion for reconsideration to set aside the default order and allow him his day in court.

RULING

The Supreme Court granted the petition. It held that the agrarian court acted harshly and abused its discretion in denying Maribojoc’s motion for reconsideration. The Court considered the equities of the case, noting Maribojoc’s ignorance, physical handicap as a paralytic, and the difficult terrain he had to traverse. Despite these challenges, he took reasonable steps to seek legal advice but received faulty guidance, leading him to believe he would be notified of the trial. The Court emphasized that agrarian courts should exercise discretion judiciously, with liberal construction of rules to achieve just, speedy, and inexpensive disposition of cases, as mandated by Section 2, Rule 1 of the Court of Agrarian Relations Rules and Section 10 of Republic Act 1267, as amended. The Court found that Maribojoc was effectively denied his day in court. Additionally, the petition was filed within the reglementary period, as it addressed the order denying the motion for relief, not the merits. The order dated October 1, 1958, was set aside, and the case was remanded to the agrarian court for trial on the merits after allowing Maribojoc time to file his answer. No costs were awarded.