G.R. No. L-24288 May 28, 1968
LEONOR MANUEL CASTILLO UDAN, petitioner, vs. THE HON. MUNICIPAL JUDGE QUIRICO C. AMON, ETC., and BEATRIZ CASTANEDA, respondents.

FACTS

Petitioner Leonor Manuel Castillo Udan filed a petition for certiorari to annul the orders of respondent Municipal Judge Quirico C. Amon. In Cadastral Case No. 12, after a hearing on June 12, 1956 where only respondent Beatriz Castañeda appeared, the court entered an order of general default and allowed Castañeda to present evidence. The following day, Tomas Manuel, grandfather of the then-minor petitioner, filed an answer claiming ownership. The court later lifted the default order and admitted petitioner’s answer. Subsequently, the trial court granted Castañeda’s motion to dismiss petitioner’s opposition and adjudicated the lots to her. Petitioner appealed to the Supreme Court (G.R. No. L-18372), which remanded the case to give petitioner an opportunity to present evidence. Upon remand, the case was assigned to respondent Judge Amon, who set it for hearing on August 27, 1964. On the day of the hearing, petitioner personally submitted her counsel’s motion for postponement to the following day, as counsel had to appear in another court. Respondent Judge denied the motion, citing non-compliance with the three-day notice rule under Rule 26, the long pendency of the case, and the principle that a lawyer should not presume a motion will be granted. The judge then revived the previous order adjudicating the property to Castañeda. Petitioner’s motions for reconsideration were subsequently denied.

ISSUE

Whether or not respondent Judge gravely abused his discretion in denying petitioner’s motion for postponement and the subsequent motions for reconsideration, and in forthwith reviving the previous order adjudicating the property to respondent Castañeda.

RULING

Yes, the Supreme Court granted the writ of certiorari. The Court held that while motions for postponement are addressed to the sound discretion of the court, such discretion must be exercised wisely to achieve substantial justice. The Court found that respondent Judge gravely abused his discretion. The motion, though filed on the day of the hearing, was the first postponement requested after the case was remanded precisely for petitioner to present evidence. Counsel’s reason—a conflicting trial commitment—was not for delay, as he requested a postponement only to the next day. The Supreme Court emphasized that procedural rules should not be applied rigidly to defeat substantial justice, and that the merit of petitioner’s claim, as recognized in the prior remand, was a significant factor. The orders dated August 27, 1964, September 26, 1964, December 4, 1964, and February 3, 1965, were set aside. Respondent Judge was ordered to reopen the proceedings to receive petitioner’s evidence.