G.R. No. 217138

G.R. No.
217138
Vitarich Corp. vs. Femina Dagmil
August 27, 2020
Facts:
Vitarich Corporation filed a civil case against Femina Dagmil seeking a sum of money at the
RTC Branch 11 of Malolos City. Femina's counsel, Atty. Nepthali Solilapsi, initially moved to dismiss the
case due to improper venue, but the RTC denied the motion and ordered Femina to file her answer.
Despite receiving this directive, Femina failed to respond within the allotted time, leading Vitarich to
seek her default. Subsequently, Femina retained new counsel, Atty. Emilio Quianzon, Jr., who filed a
motion to admit an answer on her behalf. However, before the RTC could rule on this motion, it
declared Femina in default, allowing Vitarich to present evidence unopposed. The RTC then ruled in
favor of Vitarich, ordering Femina to pay a significant sum. Femina, feeling aggrieved, sought post-
judgment relief, including a petition for relief from judgment and a motion for a new trial, both of
which were denied by the RTC. Femina then appealed to the Court of Appeals via a petition for
certiorari, which ultimately overturned the default judgment and instructed the RTC to admit Femina's
answer, remanding the case for further proceedings.
Issue:
Whether the computation presented by Vitarich reflects the true and real obligation of
Femina.
Ruling:
YES. The Supreme Court's ruling emphasized the principle of procedural fairness and the
importance of giving litigants the opportunity to present their case and defenses fully. It underscored
the discretionary power of trial courts to set aside orders of default and permit defendants to file their
answers, provided there is no showing of deliberate delay and no prejudice to the plaintiff.
The Court cited precedents such as Sablas v. Sablas, which established that it is within the
discretion of the trial court to admit an answer filed beyond the reglementary period, as long as it is
submitted before the declaration of default and there is no indication of intentional delay. The case
also highlighted the need for courts to exercise leniency in setting aside default judgments, especially
when there are prima facie meritorious defenses and no prejudice to the opposing party.
In analyzing Femina's case, the Court found that she had taken proactive steps to defend
herself, including filing a motion to admit an answer through her new counsel before the declaration
of default. The Court noted that Femina's former counsel's health issues and the secretary's mistake in
handling the case contributed to the delay in filing the answer. Despite these circumstances, Femina
demonstrated a genuine intention to participate in the proceedings and present her defenses.
Moreover, the Court observed that Vitarich Corporation did not suffer any prejudice from the
delay in filing Femina's answer. Vitarich's failure to move for default until 48 days after the expiration
of the reglementary period indicated a lack of urgency on its part. This leniency shown by Vitarich
suggested that the delay did not impede its ability to pursue its claims effectively.
The Court rejected the RTC's argument that Femina was bound by the actions of her counsel,
emphasizing that procedural rules should not be enforced rigidly at the expense of substantive justice.
It stressed that the overriding objective of the legal system is to ensure fairness and the proper
adjudication of disputes.
Furthermore, the Court addressed the distinction between Femina's case and previous rulings,
such as Hernandez v. Agoncillo, where the defendant's inexcusable neglect and deliberate delay
warranted upholding the default judgment. Unlike in Hernandez, Femina's delay in filing her answer
was due to mitigating circumstances, and she promptly sought to rectify the situation by filing post-
judgment remedies.
Ultimately, the Court affirmed the decision of the Court of Appeals to reverse the RTC's default
judgment and remand the case for further proceedings. It held that the RTC's premature judgment of
default violated Femina's right to due process and deprived her of the opportunity to present her case
fully. The ruling reiterated the judiciary's commitment to fairness and the equitable resolution of
disputes, even in the face of procedural irregularities.

G.R. No. 217138

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G.R. No. 217138

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G.R. No.

Vitarich Corp. vs. Femina Dagmil

August 27, 2020

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