It is a well-entrenched rule that generally, the client is bound by the mistakes of his lawyer. To trivialize this rule would bring about a dangerous trend of endless litigation, as parties to a case could simply change counsels and claim that due to some mistake committed by their former counsel, they are entitled to new trial.[4]
However, as held in Hilario v. People,[5] said general rule admits of certain exceptions, to wit:
x x x the exception is when the negligence of counsel is so gross, reckless and inexcusable that the client is deprived of his day in court. x x x
x x x x
If the incompetence, ignorance or inexperience of counsel is so great and the error committed as a result thereof is so serious that the client,who otherwise has a good cause, is prejudiced and denied his day in court, the litigation may be reopened to give the client another chance to present his case. In a criminal proceeding, where certain evidence was not presented because of counsel's error or incompetence, the defendant in order to secure a new trial must satisfy the court that he has a good defense and that the acquittal would in all probability have followed the introduction of the omitted evidence. What should guide judicial action is that a party be given the fullest opportunity to establish the merits of his action or defense rather than for him to lose life, liberty, honor or property on mere technicalities.[6] (Emphasis and underscoring supplied)
Clearly, for petitioner's case to be considered as an exception to the general rule, it is of utmost importance that the court be convinced that petitioner had a “good cause” in the first place, and it was merely due to his lawyer's gross negligence and incompetence that he was unjustly denied the opportunity to present it. Note, however, that as correctly pointed out by the CA, there is no showing whatsoever that petitioner had such a “good cause.”
Even during proceedings before the trial court, petitioner never presented a strong defense to persuade the court that the interest of justice would be served by the lifting of the default order. On appeal, even if petitioner (appellant below) did not assign errors with regard to the merits of the RTC decision, the CA nevertheless painstakingly reviewed the records and came to the conclusion that the evidence sufficiently supported the trial court's judgment in favor of respondent. Finally, in this petition, the arguments revolved mainly around the issue that the trial court should have been more liberal in the application of the rules by lifting the default order. Again, petitioner absolutely failed to show that he had a meritorious defense.
