Concepcion v. Cruz
REITERATIONFacts
The Antecedents: Private respondents filed an ejectment and damages case against petitioner Quirico Concepcion, claiming ownership over a parcel of land. They alleged that petitioner, in connivance with others, forcibly took possession of the land and built a house thereon. A previous case for recovery of the land (Civil Case No. 1820) was decided in favor of private respondents by the Court of Appeals. Petitioner then filed a case claiming agricultural tenancy, which was dismissed. Private respondents were placed in possession of the land via a writ of possession, but petitioner refused to vacate nor account for harvested palay, prompting private respondents to pray for demolition of petitioner's house and for him to vacate. Procedural History: The parties, assisted by counsel, submitted a Compromise Agreement dated December 18, 1969, wherein petitioner agreed to continue working on the land until December 31, 1971, with specific conditions regarding produce delivery and vacating the premises. A Supplementary Agreement specified the weight of palay. The lower court rendered judgment approving the Compromise Agreement on December 18, 1969. On April 15, 1972, a writ of execution was issued. On May 16, 1972, petitioner filed a Petition for Relief from Judgment, assailing the compromise agreement and the writ of execution. The lower court denied this petition on July 3, 1972, for being filed out of time, and on July 5, 1972, ordered the issuance of a writ of demolition. The Petition: Petitioner filed a special civil action for certiorari and prohibition with injunction, assailing the denial of his Petition for Relief and the order for demolition, attributing grave abuse of discretion to the lower court.
Issue(s)
Whether the lower court acted with grave abuse of discretion in denying petitioner's Petition for Relief from Judgment for having been filed out of time. Whether the lower court acted with grave abuse of discretion in ordering the issuance of a writ of demolition. Whether the lower court had jurisdiction over the subject matter of Civil Case No. SM-243, given petitioner's claim of tenancy.
Ruling
The Supreme Court dismissed the petition. The Court affirmed the orders of the lower court denying the Petition for Relief from Judgment and directing the issuance of a writ of demolition.
Ratio Decidendi
On the denial of the Petition for Relief from Judgment: 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 and not more than six (6) months after it was entered. This period is non-extendible and strictly enforced. In this case, the judgment approving the compromise agreement was rendered on December 18, 1969, but the petition for relief was filed on May 16, 1972, which is more than two years later. This clearly falls outside the reglementary period. The Court emphasized that the remedy of relief is an act of grace and must be availed of within the strict time frame provided by law; failure to do so is fatal. The Court cited Quijano vs. Tamenta and Turqueza vs. Hernando to underscore the finality of judgments and the strictness of the period for relief. On the writ of demolition: The order for demolition was a consequence of the executory judgment approving the compromise agreement. Since the judgment had become final and executory due to the petitioner's failure to file a timely petition for relief, the subsequent writ of execution and the order for demolition were validly issued to enforce the final judgment. The Court found no grave abuse of discretion in the issuance of the writ of demolition as it was a necessary step to implement the decision that had long become final and beyond the power of the lower court to alter. On the jurisdiction of the lower court: The Court held that the allegations in the complaint for ejectment and damages, which claimed ownership and unlawful deprivation of possession, constituted an accion publiciana, a plenary action for recovery of possession properly cognizable by the Court of First Instance. Petitioner's defense of tenancy did not automatically divest the court of jurisdiction; instead, it gave the court the authority to hear evidence to determine the tenability of the tenancy claim. However, a hearing on tenancy became unnecessary when the parties voluntarily submitted a Compromise Agreement, which the court approved. The Court found the compromise agreement to be not contrary to law, morals, or public policy, and a judgment based on such an agreement has the effect of res judicata.
Main Doctrine
A Petition for Relief from Judgment under Rule 38 must be filed within the reglementary period of sixty (60) days from knowledge of the judgment and not more than six (6) months after its entry. Failure to comply with this strict period is fatal and renders the petition unentertainable. Furthermore, a judgment approving a compromise agreement becomes final and executory upon its rendition, and the period to file a petition for relief commences from that date.