G.R. No. L-5095

LAUREANO ARZADON, plaintiff-appellant, vs. CLOTILDE ARZADON, defendant-appellee.

January 24, 1910

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FACTS:
Laureano Arzadon, as administrator of the estate of Loreza Angco, filed a complaint seeking the surrender of several rural properties. He alleged that Clotilde Arzadon and other co-defendants (Maria Luna, Basilia Corpus, and Ponciano Tacmo) unlawfully possessed these properties after Loreza Angco’s death.

During the trial in the Court of First Instance (CFI) of Ilocos Norte, the attorneys for both parties, to expedite the matter, agreed to dispense with a conventional trial and instead submitted their “allegations in writing in the form of statements of their respective witnesses.” These “proofs” were merely papers signed by counsel, containing averments from supposed witnesses.

The CFI, finding that “the whole of the allegations of the complaint have not been proven as required by law,” dismissed the complaint with respect to most of the parcels of land.

Plaintiff Laureano Arzadon appealed, assigning as error, among others, that the lower court admitted the agreement to dispense with the trial, and that it dismissed the complaint instead of finding it proven.

ISSUE:
Can parties, through their counsel, agree to dispense with a formal trial and present evidence solely through written allegations or statements of witnesses, thereby substituting these for oral testimony and proper judicial proceedings, and can such “proofs” be considered legal evidence by the court?

RULING:
No. The Supreme Court ruled that the “proofs” presented through the parties’ agreement were not legal evidence and could not be admitted.

The Court held that the agreement to dispense with a formal trial and submit written allegations as evidence constituted an open and manifest violation of the Code of Civil Procedure ( Act No. 190 ), specifically Sections 132 (establishing the order of trial), 273 (governing the manner in which evidence shall be considered, including witness credibility), 274 (providing for uniform rules of evidence in all courts), and 381 (prescribing oral testimony under oath in open court).

The Court emphasized that the order and form of a trial are not merely personal matters between the parties that they can ignore or renounce as if it only concerned them privately. Instead, the form of a trial is a matter of public order and interest, ensuring the proper administration of justice. It was erroneous for the lower court to accept such an agreement regarding the manner of offering proof.

Therefore, the judgment appealed from and all proceedings (with the exception of the initial written allegations) were set aside, and a new trial was ordered, to proceed from the time of the filing of the answer to the complaint.