Manuel v. Naoe
REITERATIONFacts
The Antecedents: On October 18, 1948, Remedios Tiong Naoe sold her one-half share of conjugal property with a right to repurchase within one year to Lorenzo Manuel. Remedios failed to redeem the property within the stipulated period, despite opportunities given beyond the agreed time. Procedural History: Manuel filed a petition for consolidation of ownership in November 1953, which was granted. He then filed an action for partition on April 5, 1954, against Remedios and Ceferino Naoe, later amended to include other heirs. After postponements, a compromise agreement was entered into on February 18, 1955, approved by the court, allowing defendants to repurchase the property for P750.00 in two installments, with failure to pay resulting in forfeiture of rights. The judgment was rendered on February 21, 1955. As defendants failed to pay the first installment, a motion for execution was granted without opposition, and the sheriff placed Manuel in possession of the property on June 24, 1955. The Appeal: On August 8, 1955, two defendants, Felicidad and Florencio Naoe, filed a petition for relief under Rule 38 of the Rules of Court, seeking to set aside the decision, arguing the compromise agreement was not binding on them as it was entered into without their consent or authority. They claimed the original contract was an equitable mortgage, not a sale with right to repurchase. The motion was denied for being filed beyond the 60-day period. The denial was appealed to the Court of Appeals, which certified the case to the Supreme Court due to questions of law.
Issue(s)
Whether the petition for relief from judgment was filed within the reglementary period prescribed by Rule 38 of the Rules of Court. Whether the issues raised by the petitioners regarding the nature of the contract and the consolidation of ownership are barred by res judicata.
Ruling
The Supreme Court affirmed the order of the trial court denying the petition for relief from judgment. The Court held that the petition was filed out of time and that the issues raised were already decided in a previous case, thus constituting res judicata.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition for relief from judgment was filed out of time. The decision based on the compromise agreement was rendered on February 21, 1955, and the appellants, through their counsel, were duly notified. The execution of the judgment, placing the appellee in possession, occurred on June 24, 1955. However, the petition for relief was only filed on August 8, 1955, which is almost six months after the rendition of the decision and well beyond the 60-day period prescribed by Rule 38 of the Rules of Court. The Court reiterated that notice to counsel of record is notice to the parties, and the appellants' claim of not being notified was unsubstantiated given that their counsel was notified and their mother, Remedios Tiong Naoe, who acted in their behalf, was also notified. On Issue 2: The Supreme Court ruled that the special defense the appellants sought to prove, namely, that the pacto de retro sale was annullable and intended as an equitable mortgage, and that the plaintiff could not legally acquire the western portion because it was undivided, had already been passed upon in Civil Case No. 12770. In that case, the transaction was declared a sale with right to repurchase, and the ownership of the appellee was consolidated over one-half of the undivided western portion of the land. Therefore, these issues were already decided by a competent court and are now barred by the principle of res judicata, preventing their relitigation.
Main Doctrine
The Supreme Court affirmed the trial court's denial of a petition for relief from judgment, holding that the petition was filed out of time. The Court emphasized that notice to counsel of record is notice to the parties, and the appellants were aware of the judgment as early as February 18, 1955, but filed their petition for relief only on August 8, 1955, exceeding the 60-day period prescribed by Rule 38 of the Rules of Court. Furthermore, the Court ruled that the issue of whether the transaction was a pacto de retro sale or an equitable mortgage, and the consolidation of ownership, were already decided in a previous case (Civil Case No. 12770), thus constituting res judicata.