### Facts:
The case originated from two civil actions for damages filed by respondents Francisca Timosa and Chiveniano Go against petitioners Shell Company of the Philippines and individuals Numeriano Jacolo, Ernesto Dedel, and Jacinto Monoy in the Court of First Instance (CFI) of Agusan, presided by respondent Judge Manuel Lopez Enage. Errors in notifying the legal counsel of the petitioners led them to claim a lack of due process since they were not properly heard before decisions were rendered against them. Summons was served correctly, but subsequent notices were misdirected due to confusion in the identity of counsel representing the parties. This resulted in the absence of the petitioners’ defense during trials and the controversial awarding of damages by the judge without the defendants’ knowledge or participation. The procedural journey included failed notifications, multiple failed attempts by the petitioners to present their defense due to scheduling issues, and an apparent misunderstanding leading to a denial of a postponement request, further contributing to the assertion of a due process violation.
### Issues:
1. Whether the failure to properly notify the petitioners’ counsel of record violated their right to due process.
2. Whether the denial of the request for postponement to the petitioners Jacobo, Dedel, and Monoy constitutes a denial of due process.
3. Whether the decisions rendered by respondent Judge Enage should be nullified and set aside for lack of procedural due process.
### Court’s Decision:
The Supreme Court granted the writs of certiorari, nullifying the decisions dated August 26, 1968, and September 30, 1968, for lacking procedural due process. The Court found that counsel for the petitioner Shell Company was not notified of the proceedings, attributing to a clear denial of due process. Furthermore, it observed that while the request for postponement by petitioners Jacolo, Dedel, and Monoy could be subject to discretion, the circumstances warranted a more lenient application, highlighting that their failure to present evidence was not due to inexcusable neglect. The Court emphasized the constitutional guarantee of procedural due process, which mandates that parties in a legal proceeding must be given an opportunity to be heard.
### Doctrine:
This case reaffirms the doctrine that the failure to notify a party’s counsel of record as well as the unjust denial of a request for postponement violate the due process clause of the Constitution. It underscores the principle that due process is satisfied only if a competent court, with jurisdiction and without bias, ensures that the parties involved are accorded the right to be heard at every stage of the proceeding.
### Class Notes:
– **Due Process**: Ensures that all parties must be given an opportunity to be heard in a competent court possessing jurisdiction, free from bias.
– **Notification of Counsel**: Correct and timely notification of legal counsel is essential for the fulfillment of due process.
– **Request for Postponement**: While generally discretionary, requests for postponements should be considered with a view towards ensuring justice and fair play, especially when failure to hear evidence is not due to neglect by the party requesting it.
– **Certiorari**: A procedural remedy granted when a court acts with grave abuse of discretion, amounting to lack or excess of jurisdiction; in this case, used to nullify decisions rendered without due process.
### Historical Background:
This case illustrates the crucial importance of procedural due process within the Philippine legal system, highlighting the adherence to principles that ensure fairness and justice in judicial proceedings. It reflects on the judiciary’s role in balancing discretion with the imperative necessity to uphold constitutional rights, serving as a reminder of the courts’ duty to prevent miscarriage of justice and respect the due process clause enshrined in the Philippines Constitution.
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