Domingo v. De la Cruz
REITERATIONFacts
The Antecedents: Plaintiffs, descendants of Eustaquio Beltran's first marriage, sought partition of real properties and bank deposits, claiming they were conjugal assets of Eustaquio Beltran and his second wife, Pelagia de la Cruz. Plaintiffs alleged Eustaquio Beltran brought ten hectares of rice lands into the marriage, from which the couple purchased two lots. Pelagia de la Cruz later sold one lot and used the proceeds to purchase other properties and make bank deposits. Defendants, collateral heirs of Pelagia de la Cruz, countered that the rice lands did not belong to Eustaquio Beltran, and the purchased lots were acquired by Pelagia de la Cruz with her own funds, with one lot being a government Friar Land purchased on installment, with title issued solely to her. Procedural History: The case originated in the Court of First Instance of Rizal as Civil Case No. Q-7270. Defendants filed a request for admission regarding the ownership of the rice lands, which plaintiffs failed to deny under oath, leading defendants to move for summary judgment. The lower court granted summary judgment in favor of the defendants on June 8, 1964, dismissing the case. Plaintiffs subsequently filed a petition for relief from judgment on October 23, 1964, alleging fraud by the defendants in connivance with one of the plaintiffs. Defendants opposed the petition, arguing it was filed beyond the statutory period and lacked sufficient grounds. The lower court denied the petition for relief on December 11, 1964, citing the late filing, as it was filed 125 days after plaintiffs learned of the judgment. A motion for reconsideration of this denial was also unsuccessful. The Petition: Plaintiff-appellant appealed the denial of his petition for relief from judgment. The core issue on appeal was whether the petition for relief was filed within the prescribed period under Section 3 of Rule 38 of the Rules of Court, which requires filing within sixty days of learning of the judgment and not more than six months after its entry, accompanied by affidavits showing fraud and a substantial cause of action. The appellant argued that the sixty-day period should be counted from the denial of a motion for reconsideration filed on July 20, 1964. However, the appellate court found no evidence of such a motion in the record and affirmed the lower court's finding that the petition was filed 125 days after notice of the judgment, thus rendering it untimely. The court also found the alleged fraud unsubstantiated, attributing the situation to an intramural misunderstanding among the plaintiffs regarding legal representation and noting that the failure to file a memorandum or opposing affidavits was the primary reason for the summary judgment, not extrinsic fraud.
Issue(s)
Whether the petition for relief from judgment was filed within the reglementary period. Whether the alleged fraud constituted extrinsic fraud warranting relief from judgment.
Ruling
The Supreme Court affirmed the order of the lower court denying the petition for relief from judgment. The Court held that the petition was filed beyond the 60-day period prescribed by Rule 38, Section 3 of the Rules of Court. The Court also found no sufficient evidence of extrinsic fraud and noted that the alleged procedural missteps did not constitute fraud that would vitiate the judgment.
Ratio Decidendi
On the timeliness of the petition for relief: The Court reiterated that a petition for relief under Rule 38 must be filed within sixty (60) days after the petitioner learns of the judgment, order, or proceeding to be set aside, and not more than six (6) months after such judgment or order was entered. In this case, the judgment was rendered on June 8, 1964, and plaintiffs were served a copy on June 20, 1964. The petition for relief was filed on October 23, 1964, which is 125 days after they learned of the judgment. This clearly exceeds the 60-day period. The Court found no merit in the argument that the period should be counted from the denial of a motion for reconsideration, as there was no record of such a motion being filed. The Court emphasized that the procedural periods are mandatory and must be strictly complied with. On the alleged fraud: The Court found that the alleged fraud did not constitute extrinsic fraud. The claims regarding Victoriano Beltran's misrepresentation and Atty. Ubarra's alleged inability to prosecute the plaintiffs' interests were deemed insufficient to set aside a judgment. The Court noted that the failure to file a memorandum was not indicative of connivance and that the other plaintiffs did not appear to feel defrauded, suggesting an internal misunderstanding among them regarding counsel. Furthermore, the Court pointed out that the summary judgment was primarily based on the plaintiffs' failure to specifically deny matters requested for admission under oath and their failure to submit opposing affidavits, not on any fraudulent misrepresentation by the defendants. The Court also observed that the counsel who filed the motion for reconsideration after the summary judgment did not raise the issue of fraud, thereby waiving it.
Main Doctrine
The Supreme Court affirmed the dismissal of a petition for relief from judgment due to its late filing. The Court emphasized that the 60-day period for filing such a petition commences from the date the petitioner learns of the judgment, and not from the denial of a motion for reconsideration unless such motion is properly filed and recorded. Furthermore, the Court highlighted that allegations of fraud must be extrinsic and supported by sufficient evidence, and that procedural rules, particularly those concerning time limits, must be strictly observed.