Francisco v. Aquino
REITERATIONFacts
The Antecedents: On September 30, 1940, Pedro Francisco executed a Deed of Absolute Sale over Lot No. 3163 of the Morong Cadastre to Aquilino Tungke for P200.00. The deed was registered on November 11, 1943. Procedural History: a. Ejectment Case (Civil Case No. 5908): Pedro Francisco filed an ejectment case against Aquilino Tungke in the Municipal Court of Morong, which was dismissed. Upon appeal to the Court of First Instance (CFI) of Rizal, Branch X, the case was again dismissed on August 13, 1964, for failure of the plaintiff to prosecute. This dismissal order became final. b. Annulment of Sale (Civil Case No. 6558): Pedro Francisco filed a case to annul the Deed of Absolute Sale, which was also dismissed on February 7, 1964, due to his repeated failure to appear. This dismissal also became final. c. Reopening of Ejectment Case: In November 1964, Pedro Francisco filed a motion to reconsider the dismissal of Civil Case No. 5908. Despite the order of dismissal having become final, the CFI, Branch X, granted the motion, set aside the dismissal, and rendered a judgment on February 2, 1965, ordering Tungke to vacate and pay rentals. Tungke's petition for relief was denied. d. Action to Annul Judgment (Civil Case No. 8806): Consequently, Aquilino Tungke filed an action to annul the February 2, 1965 judgment in Civil Case No. 5908, arguing that the court exceeded its authority in setting aside a final order of dismissal. This case was assigned to CFI, Branch VIII. e. Action to Quiet Title (Civil Case No. 8926): Aquilino Tungke also filed an action to quiet title over Lot No. 3163, assigned to CFI, Branch VIII. The cases were jointly tried. Pedro Francisco died during the proceedings, and his heirs (petitioners) were substituted. On August 25, 1970, CFI, Branch VIII, rendered judgment in Civil Cases Nos. 8806 and 8926, declaring Tungke the absolute owner of Lot No. 3163 and ordering the defendants to vacate and pay damages. A motion for execution was granted. The Petition: Petitioners filed a petition for certiorari with prohibition, contending that CFI, Branch VIII, acted without jurisdiction in annulling the judgment of CFI, Branch X.
Issue(s)
Whether the Court of First Instance of Rizal, Branch VIII, has the authority and jurisdiction to take cognizance of and act upon an action to annul a final and executory judgment rendered by another branch of the same Court of First Instance. Whether the Court of First Instance, Branch X, exceeded its authority in setting aside the order of dismissal dated August 13, 1964, in Civil Case No. 5908, which had already become final. Whether the judgment rendered by the Court of First Instance, Branch X, on February 2, 1965, in Civil Case No. 5908, is valid. Whether the Court of First Instance, Branch VIII, acted within its jurisdiction in rendering judgment in Civil Cases Nos. 8806 and 8926, particularly in declaring Aquilino Tungke as the absolute owner of Lot No. 3163.
Ruling
The petition for certiorari with prohibition is DENIED. The Court of First Instance of Rizal, Branch VIII, acted within its judicial competence and authority in taking cognizance of Civil Cases Nos. 8806 and 8926. The order of dismissal in Civil Case No. 5908, dated August 13, 1964, had become final, and the court exceeded its authority in setting it aside and rendering a subsequent judgment.
Ratio Decidendi
On the jurisdiction to annul judgments of coordinate branches: The Court reiterated the rule established in Dulap v. Court of Appeals that a court of first instance or a branch thereof has the authority and jurisdiction to take cognizance of, and to act in, a suit to annul a final and executory judgment or order rendered by another court of first instance or by another branch of the same court. The Court emphasized that different branches of a court of first instance are coordinate and co-equal courts, and the totality of which constitutes only one court of first instance. Therefore, the venue of actions should not be disregarded simply to prevent one court from taking cognizance of an action to annul the judgment of another court of concurrent jurisdiction or of another branch. The policy of judicial stability should be subordinate to an orderly administration of justice based on existing rules of procedure and law. On the finality of the dismissal order in Civil Case No. 5908: The Court held that the order of dismissal dated August 13, 1964, in Civil Case No. 5908, was a final order as it finally disposed of the rights of the parties. Since this order was not reconsidered or amended within the thirty-day period provided by the rules, it became final as a matter of course. The motion for reconsideration filed by Pedro Francisco in November 1964 was filed long after the order of dismissal had become final. Consequently, the court exceeded its authority in setting aside the final order of dismissal on November 9, 1964, and in rendering the subsequent judgment on February 2, 1965. On the validity of the judgment in Civil Case No. 5908: Due to the court exceeding its authority in setting aside a final and executory order of dismissal, the subsequent judgment rendered in Civil Case No. 5908 on February 2, 1965, reversing the decision of the municipal court, was consequently invalid. The court's action in reopening a case after its dismissal order had become final was an act beyond its jurisdiction. On the jurisdiction of Branch VIII in Civil Cases Nos. 8806 and 8926: The Court found that respondent court, in taking cognizance of Civil Cases Nos. 8806 (action to annul judgment) and 8926 (action to quiet title), did not gravely abuse its discretion but acted within its judicial competence and authority. While the action to annul the judgment of February 2, 1965, was the subject of Civil Case No. 8806, the court in Civil Cases Nos. 8806 and 8926 limited itself to the issues involved in the action to quiet title (Civil Case No. 8926). It declared Aquilino Tungke as the absolute owner of Lot No. 3163 based on the evidence presented, which was within the jurisdictional authority and competence of the court. The Court noted that the action to quiet title was concededly within the court's jurisdiction.
Main Doctrine
A court of first instance or a branch thereof has the authority and jurisdiction to take cognizance of, and to act in, a suit to annul a final and executory judgment or order rendered by another court of first instance or by another branch of the same court, as different branches of a court of first instance are coordinate and co-equal courts.