What is the test for a motion to set aside a default judgment?

This analysis fails. As discussed in part C., infra, the defendants' motions implicitly included a request for relief from the default judgments entered against them. It is also true that to support a motion for relief "from a judgment, dismissal, order, or other proceeding taken against him or her through his or her mistake, inadvertence, surprise, or excusable neglect" ( 473, 3d par.), the moving party must show good cause for that relief by proving the existence of "a satisfactory excuse for the occurrence of that mistake." (Billings v. Health Plan of America (1990) 225 Cal.App.3d 250, 255, 275 Cal.Rptr. 80.)

[24 Cal.App.4th 1441] However, because the defendants' motions were brought over six months after the judgments were entered, any relief based upon a mistaken failure to respond to the summons was no longer available. ( 473, 3d par.) Moreover, rather than allege any mistake, the defendants argued that the judgment is void because of Dill's failure to establish personal jurisdiction over them. Accordingly, their motions were based on the sixth paragraph of section 473: "The court ... may, on motion of either party after notice to the other party, set aside any void judgment or order." (See People v. A.T.L., Inc. (1957) 150 Cal.App.2d 152, 153, 309 P.2d 552.)

Once six months have elapsed since the entry of a judgment, a trial court may grant a motion to set aside that judgment as void only if the judgment is void on its face. (Morgan v. Clapp (1929) 207 Cal. 221, 224, 277 P. 490.) "A judgment or order is said to be void on its face when the invalidity is apparent upon an inspection of the judgment-roll." (Ibid.) In a case in which the defendant does not answer the complaint, the judgment roll includes the proof of service. ( 670, subd. (a).) Thus, in a motion under the sixth paragraph of section 473, the moving defendant need make no evidentiary showing whatsoever, so long as the jurisdictional defect is shown by the proof of service.