G.R. No. L-59283. July 30, 1982.
SPOUSES CRISANTO MOLINO and LORETO MOLINO, petitioners, vs. HON. COURT OF APPEALS, HON. ERNESTO M. MENDOZA, DISTRICT JUDGE CAR FIFTEENTH REGIONAL DISTRICT BRANCH II, SURIGAO CITY, HEIRS OF NICOLASA QUINTOS BY ROSITA Q. PIMENTEL, respondents.

FACTS

Private respondents filed a CAR case against petitioners for recovery of possession of leased agricultural land. During the scheduled hearing, petitioners and their counsel failed to appear despite due notice. Their counsel filed a telegraphic motion to reset the hearing, which the court denied for lack of merit. The trial court, invoking Section 17 of P.D. No. 946, proceeded with an ex-parte trial and rendered judgment in favor of the plaintiffs. Petitioners filed a motion for reconsideration, arguing that the ex-parte trial violated their right to due process. The CAR denied the motion, stating that the motion for reconsideration did not conform to the allowable grounds under the Uniform Rules of Procedures of the CAR, which are limited to whether findings are unsupported by substantial evidence or conclusions are contrary to law.
Petitioners appealed to the Court of Appeals, which affirmed the CAR judgment solely on the ground that it was supported by substantial evidence, without addressing the due process issue raised in the motion for reconsideration.

ISSUE

Whether the ex-parte trial conducted by the Court of Agrarian Relations, due to the absence of petitioners and their counsel despite notice, constituted a denial of due process.

RULING

No, the ex-parte trial was legal and did not violate due process. The Supreme Court affirmed the decisions of the lower courts. The legal logic centers on the interpretation of P.D. No. 946, which governs agrarian relations procedure. The decree’s paramount objective, as stated in its preamble, is to achieve a “just, expeditious and inexpensive disposition of agrarian cases,” with “speedy disposition” being a key phrase. To prevent interminable delays, Section 17 explicitly provides that “the absence of counsel of any or both the parties shall not be a ground for postponement or continuance, provided they were duly notified.” Since petitioners and their counsel were duly notified of the hearing, the trial court acted within its statutory authority in proceeding ex-parte upon their unjustified absence.
The Court further held that this procedural rule is reasonable and has a constitutional counterpart, thereby satisfying due process requirements. It cited Article IV, Section 19 of the 1973 Constitution, which allowed trial to proceed notwithstanding the absence of the accused if duly notified and the absence is unjustified. By analogy, the statutory provision for agrarian cases is a valid procedural tool to prevent delay, not a denial of fundamental fairness. The petitioners were given notice and an opportunity to be heard; their failure to avail themselves of that opportunity, without a substantiated justification (as their mere telegraphic motion lacked a supporting medical certificate), was at their own peril. Consequently, the petition was denied for lack of merit.