Aguilos v. Sepulveda
REITERATIONFacts
1. The Antecedents: Respondent Remigio Capaycapay filed suit against Encarnacion H. Aguilos, alleging he was a tenant since 1927 of a four-hectare landholding owned by Celestino Hallera, who was succeeded by his daughter Encarnacion. Capaycapay claimed Encarnacion ejected him and replaced him with co-defendants Juan Timon and Alex Timon. The defendants' answer did not dispute his tenancy but claimed voluntary abandonment and sought damages. A partial stipulation of facts recognized Encarnacion was not the sole owner, and her sisters were co-owners, leading to an amended complaint impleading them. 2. Procedural History: Following an amended complaint impleading Encarnacion's sisters as co-defendants, and their failure to appear at a scheduled hearing despite notice to their counsel, Atty. Lauron, the agrarian court declared them in default and proceeded ex parte. A decision was rendered on July 25, 1967, reinstating Capaycapay, ejecting the Timons, and ordering Encarnacion to pay damages. Motions for new trial and reconsideration were denied. A writ of execution was issued. Subsequently, all defendants filed a petition for certiorari and mandamus with preliminary injunction in the Supreme Court, which was dismissed. A supplemental petition/second motion for reconsideration was filed by the co-owner sisters, which this Court treated as an amended petition. 3. The Petition: The petitioners, the co-owner sisters, seek to nullify the judgment and orders of the agrarian court. They argue they were deprived of their day in court as they were impleaded in the amended complaint without proper service of summons, and that the court never acquired jurisdiction over their persons. They claim they never authorized Atty. Lauron to represent them. The Supreme Court found that the petitioners waived the requirement of summons by voluntarily submitting to the court's jurisdiction through the appearance of counsel, first Atty. Lauron and later Attys. Tamaca and Aguilos, Jr., who even filed an earlier petition in the Supreme Court on behalf of all defendants without questioning the lack of summons. The Court also noted that the judgment's monetary liabilities were solely against Encarnacion, and the reinstatement order was binding on all co-owners as Encarnacion acted as administrator-manager.
Issue(s)
Whether the agrarian court acquired jurisdiction over the persons of the petitioners (new defendants) despite the lack of service of summons. Whether the judgment ordering the reinstatement of respondent Capaycapay prejudiced the petitioners as co-owners.
Ruling
The petition for certiorari and mandamus is dismissed. The Supreme Court held that the petitioners waived the requirement of summons by voluntarily submitting to the jurisdiction of the agrarian court through the appearance of their counsels, Atty. Lauron and later Attys. Tamaca and Aguilos, Jr. The Court also found that the judgment ordering the reinstatement of respondent Capaycapay did not prejudice the petitioners, as Encarnacion Hallera, acting as administrator-manager, was solely responsible for the ejectment, and the judgment against her had become final and executory.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the petitioners had waived their right to be served with summons. While ordinarily, service of summons is necessary for a court to acquire jurisdiction over a party's person, this requirement can be waived. The petitioners, through their counsel Atty. Lauron, filed an amended answer on their behalf. Furthermore, after the judgment, new counsels, Attys. Tamaca and Aguilos, Jr., filed a supplemental pleading and a motion to reconsider the denial of the motion for new trial, all of which indicated their voluntary submission to the agrarian court's jurisdiction. The belated claim that Atty. Lauron was not authorized to represent them was not raised in the lower court and could not be raised for the first time in the Supreme Court. The Court cited Rule 14, Section 23 of the Rules of Court, which states that voluntary appearance in court is equivalent to service of summons. On Issue 2: The Supreme Court found that the petitioners' claim of prejudice due to the reinstatement of respondent Capaycapay was untenable. The judgment ordering reinstatement was rendered against Encarnacion H. Aguilos, who was found to be the administrator-manager of the landholding. The agrarian court's decision explicitly stated that Encarnacion was solely liable for the obligations incurred by her deceased father and did not make a finding that she had a right to seek reimbursement from her co-heirs. Any claim for reimbursement by Encarnacion against the petitioners would have to be pursued in a separate action. Moreover, the judgment ordering Capaycapay's reinstatement had long become final and executory, and the petitioners' argument that Capaycapay was no longer interested in his reinstatement was dismissed, as the lower court accepted Capaycapay's explanation that his disclaimer was due to threats from Encarnacion.
Main Doctrine
The Supreme Court reiterated that a party waives the right to be served with summons by voluntarily submitting to the court's jurisdiction through the appearance of counsel and the filing of pleadings. This voluntary submission cures any defect in the service of process. The Court also emphasized the finality of judgments, stating that issues that could have been raised in a timely appeal cannot be relitigated via a petition for certiorari and mandamus after the judgment has become executory. The ruling also clarified that an administrator's liability for ejectment and damages does not automatically entitle them to reimbursement from co-heirs, as such claims must be pursued in separate proceedings.