Macabingkil v. People's Homesite & Housing Corp.
REITERATIONFacts
The Antecedents: Concepcion Macabingkil filed a complaint for specific performance with preliminary injunction against the People's Homesite & Housing Corporation (PHHC), seeking to compel PHHC to execute a Deed of Conditional Contract to Sell Lot No. 27, Block E-148, East Avenue Subdivision, Quezon City, based on PHHC Board Resolution No. 550. She also sought to enjoin PHHC and others from ejecting her or demolishing her house. Procedural History: Spouses Irene de Leon and Vicente Llanes intervened, claiming the lot was sold to them by PHHC pursuant to a final judgment in Civil Case No. Q-5866, which declared PHHC Resolution No. 550 void and enjoined PHHC from respecting a prior Conditional Contract to Sell executed in favor of De Leon. The trial court granted the intervention. PHHC filed an answer with counterclaim, asserting that Macabingkil was a squatter and that Resolution No. 550 was already declared null and void. PHHC raised affirmative defenses, including lack of cause of action and bar by prior judgment. The intervenors adopted PHHC's affirmative defenses. After preliminary hearing, the trial court dismissed Macabingkil's complaint for failure to state a cause of action, citing the prior Court of Appeals decision in CA-G.R. No. 31169-R which declared Resolution No. 550 void and upheld the contract with De Leon. Macabingkil appealed to the Court of Appeals, which affirmed the trial court's dismissal. The Petition: Macabingkil appealed to the Supreme Court, arguing that the Court of Appeals erred in affirming the dismissal, in holding that her complaint stated no cause of action, and in declaring Board Resolution No. 550 void.
Issue(s)
Whether the appeal was perfected within the reglementary period. Whether the Court of Appeals acted without or in excess of jurisdiction or with grave abuse of discretion in affirming the dismissal of the complaint for failure to state a cause of action. Whether the prior judgment in Civil Case No. Q-5866, affirmed in CA-G.R. No. 31169-R, is binding on Concepcion Macabingkil, who was not a party to that case. Whether Concepcion Macabingkil's complaint stated a valid cause of action.
Ruling
The Supreme Court dismissed the appeal. The Court held that the appeal was filed out of time, rendering the judgment of the Court of Appeals final and executory. Even if treated as a petition for certiorari, the Court found no grave abuse of discretion, as the dismissal was based on a prior final and executory judgment that declared the basis of Macabingkil's claim (PHHC Board Resolution No. 550) void and upheld the contract to sell in favor of Irene de Leon. The Court reiterated that a final judgment cannot be relitigated and that a judgment void on its face can only be attacked directly, not collaterally.
Ratio Decidendi
On the timeliness of the appeal: The Court found that Concepcion Macabingkil's counsel received the Court of Appeals' decision on March 8, 1968. Her first motion for reconsideration was filed on March 25, 1968, which was 17 days after receipt, thus exceeding the 15-day reglementary period. Consequently, the judgment had already become final and executory. The Court emphasized that the perfection of an appeal within the period prescribed by law is mandatory and jurisdictional. Failure to do so renders the judgment final and executory, and the time for appeal cannot be extended without a prior motion for extension filed within the original period. On whether the Court of Appeals acted without or in excess of jurisdiction or with grave abuse of discretion: The Court held that the Court of Appeals did not act with grave abuse of discretion. The dismissal of Macabingkil's complaint was based on the principle of res judicata and conclusiveness of judgment, stemming from a prior case (Civil Case No. Q-5866, affirmed in CA-G.R. No. 31169-R) where PHHC Board Resolution No. 550, the very basis of Macabingkil's claim, was declared void and of no effect. The Court found that the prior judgment had already resolved the issue of who was the rightful awardee of the lot, upholding Irene de Leon's contract to sell. Therefore, affirming the dismissal for failure to state a cause of action was a proper exercise of jurisdiction. On whether the prior judgment is binding on Concepcion Macabingkil: While acknowledging that Macabingkil was not a party to the prior case (Civil Case No. Q-5866), the Court explained that the judgment in that case, which declared PHHC Board Resolution No. 550 void, was still binding in effect. This is because the subject matter of that case was the same lot in dispute. The declaration that Resolution No. 550 was void disabled PHHC from disposing of the same property to Macabingkil. The Court stated that Macabingkil's recourse would have been a direct action to annul the prior judgment, not a collateral attack through a new complaint based on the void resolution. On whether Concepcion Macabingkil's complaint stated a valid cause of action: The Court concluded that the complaint did not state a valid cause of action. This was primarily because the foundation of her claim, PHHC Board Resolution No. 550, had been declared null and void by a prior final and executory judgment. The Court reiterated that to re-award the lot to Macabingkil would mean ignoring a valid and final judgment. Furthermore, the Court noted that Macabingkil had previously been offered another lot (Lot No. 15) and had accepted it, which contradicted her claim of being unfairly treated and supported the PHHC's policy of awarding only one lot per family.
Main Doctrine
A judgment that has become final and executory cannot be relitigated on its merits. A party not impleaded in a prior case may not be bound by the judgment, but if the subject matter is the same and the judgment declared void the basis of the subsequent claim, the prior judgment effectively prevents the disposition of the property to a third party. The validity of a final and executory judgment may only be attacked directly, not collaterally, except when the judgment is void on its face.