Villeza v. Olmedo
REITERATIONFacts
1. The Antecedents: Patricio Villeza initiated an action against Jesus Olmedo and Tiu Tin alias Penga to recover ownership and possession of a parcel of land. The Court of First Instance of Leyte ruled in favor of Villeza, declaring him the owner, ordering the defendants to deliver possession, and condemning them to pay damages for copra and nipa, as well as annual payments for continued possession, plus costs. 2. Procedural History: The Court of Appeals affirmed the trial court's decision, with a modification to the damages awarded. Following the remand of the case, Tiu Tin filed a petition for relief from judgment, alleging he was unaware of being a co-defendant, had not been served pleadings, lacked proper legal representation, and was denied his day in court. He claimed his co-defendant, Olmedo, had assured him he was merely a witness and that Olmedo would handle the litigation. The trial court denied this petition, finding that Tiu Tin had been duly summoned, represented by counsel, and had participated in the proceedings, including testifying and appealing. The court noted that any reliance on Olmedo's assurances was a matter between Tiu Tin and Olmedo, or Tiu Tin and his counsel, and that the petition for relief was filed beyond the statutory limit. 3. The Petition: Tiu Tin appealed the denial of his petition for relief. In his brief, he argued that the judgment was void for want of due process. However, the appellate court found no merit in these assertions, as the record indicated Tiu Tin was summoned, represented by counsel, and that the original decision contained findings of fact and law. The court concluded that Tiu Tin's claims of fraud by his co-defendant, even if true, could not affect the plaintiff's rights, as the judgment was obtained after trial and submission of evidence. The order denying relief was affirmed.
Issue(s)
Whether Tiu Tin is entitled to relief from the judgment. Whether the judgment is void for want of due process.
Ruling
The Court affirmed the order denying the petition for relief from judgment, with costs against the appellant.
Ratio Decidendi
On the entitlement to relief from judgment: The Court found that Tiu Tin was not entitled to relief from judgment. The records clearly showed that he was duly summoned, received a copy of the complaint, was represented by counsel (Atty. Ciriaco V. Tupaz) who filed a motion to dismiss and an answer on his behalf, and even testified in the case. His claim of ignorance or lack of day in court was contradicted by these facts. Furthermore, his petition for relief was filed beyond the reglementary period provided by Rule 38 of the Rules of Court. The Court emphasized that if Tiu Tin was indeed misled by his co-defendant Olmedo, his recourse would be against Olmedo or his counsel, not to set aside a judgment that had become final and was validly obtained by the plaintiff. On the alleged voidness of the judgment for want of due process: The Court held that the judgment was not void for want of due process. The findings of fact and law by the Court of Appeals were supported by the records. Tiu Tin was properly summoned and represented by counsel throughout the proceedings. The suit involved land in Abuyog, Leyte, and the proceedings were conducted in that jurisdiction. Therefore, his assertions of invalidity based on lack of due process were unsubstantiated. The Court also noted that even if Tiu Tin were a victim of fraud by his co-defendant, such fraud would not affect the rights of the plaintiff who had obtained a valid judgment after trial and presentation of sufficient evidence, unless there was collusion between the co-defendant and the plaintiff, which was not alleged.
Main Doctrine
A petition for relief from judgment under Rule 38 must be filed within the reglementary period. Allegations of fraud or mistake by a co-defendant do not affect the rights of a plaintiff who has obtained a valid judgment after trial, unless collusion between the co-defendant and the plaintiff is proven.