G.R. No. L-2900
MAXIMO CORTES, Plaintiff-Appellee, vs. MANILA JOCKEY CLUB, ET AL., Defendants-Appellants.
October 23, 1906

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FACTS:
1. Plaintiff’s Allegations: Maximo Cortes filed a complaint on August 11, 1905, seeking mandamus to compel the Manila Jockey Club to reinstate his membership, from which he was allegedly unlawfully expelled. He also demanded ₱5,000 in damages and requested an expedited proceeding.
2. Procedural History:
– The Court of First Instance of Manila ordered defendants to answer or demur within six days (later extended by six more days).
– Defendants demurred (challenged legal sufficiency), but the court overruled it and required an answer within one day.
– Defendants failed to answer, and the court rendered default judgment in favor of Cortes, ordering reinstatement and awarding ₱500 in damages.
– Defendants appealed, citing procedural errors and insufficiency of the complaint.

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ISSUES:
1. Procedural Errors:
– Did the trial court abuse its discretion in expediting proceedings and denying defendants adequate time to respond?
– Was the default judgment proper given defendants’ failure to answer?
2. Substantive Issues:
– Did the complaint state a valid cause of action for mandamus?
– Was prior demand necessary before filing for mandamus?
– Were the board members properly joined as defendants?

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RULING:
1. Procedural Fairness:
– The court did not abuse its discretion in expediting proceedings under Section 230 of the Code of Civil Procedure.
– Defendants had notice and opportunities to seek extensions but voluntarily withdrew after their motion for a change of venue was denied.

2. Sufficiency of Complaint:
– The complaint sufficiently alleged a legal duty by the Jockey Club to reinstate Cortes.
– Joinder of board members was proper since they administered the Club’s affairs and participated in the expulsion.

3. Prior Demand for Mandamus:
– Defendants waived the objection by not raising it earlier.
– Under prevailing authority, formal demand is not always required if the refusal is implied by conduct (e.g., continued exclusion).

4. Judgment Affirmed:
– The default judgment and writ of mandamus were upheld.
– Damages of ₱500 were deemed appropriate.

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Disposition: The Supreme Court affirmed the trial court’s judgment, with costs against appellants. The case was remanded for execution.

Concurring Justices: Arellano (C.J.), Mapa, Johnson, Tracey. Willard concurred in result. Torres did not participate.

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Key Doctrine:
– Courts may expedite proceedings in mandamus cases under Section 230, Code of Civil Procedure.
– Joinder of corporate officers is proper if they actively enforce the disputed action.
– Prior demand may be excused if the defendant’s conduct renders it futile.

(Note: This digest condenses the case for clarity while retaining legal essentials.)