Malia v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a civil case filed by Ambrocio Malia against Basilia Malia and other individuals, along with the Municipality of Noveleta. The suit sought the annulment of a partition with sale, annulment of a donation, and reconveyance with damages, including a request for a preliminary injunction. Ambrocio Malia passed away during the proceedings and was substituted by his heirs, the petitioners in this case. 2. Procedural History: The Court of First Instance of Cavite initially ruled in favor of the substituted plaintiffs against the individual defendants but declared a Deed of Donation executed in favor of the Municipality of Noveleta as valid and binding. The individual defendants appealed to the Intermediate Appellate Court (IAC). The Municipality of Noveleta did not appeal the favorable judgment, nor did the substituted plaintiffs appeal the judgment against them concerning the municipality. The IAC affirmed the trial court's decision in its entirety, noting that the portion of the judgment in favor of the Municipality of Noveleta had become final due to the lack of an appeal by the substituted plaintiffs. 3. The Petition: The substituted plaintiffs, now the petitioners, filed a petition seeking to reverse the decision of the Intermediate Appellate Court specifically concerning the judgment rendered in favor of the Municipality of Noveleta. They argued that this portion of the judgment should not have been considered final. The Supreme Court, after deliberation, resolved to dismiss the petition for lack of merit, holding that the judgment in favor of the Municipality of Noveleta had indeed attained finality as it was not appealed by the substituted plaintiffs.
Issue(s)
Whether the judgment in favor of the Municipality of Noveleta attained finality. Whether the substituted plaintiffs could still appeal the judgment in favor of the Municipality of Noveleta after failing to appeal it in the lower courts.
Ruling
The petition is dismissed for lack of merit. The judgment in favor of the Municipality of Noveleta attained finality when the substituted plaintiffs did not appeal it.
Ratio Decidendi
On the finality of the judgment in favor of the Municipality of Noveleta: The Court held that the judgment in favor of the Municipality of Noveleta, whether correct or not, had attained finality. This was because the substituted plaintiffs, who were the parties against whom this portion of the judgment was rendered, did not file an appeal from the decision of the trial court. The Intermediate Appellate Court correctly noted that a judgment that has become final and executory can no longer be modified or set aside by any court, in line with the principle of immutability of judgments. On the right to appeal the judgment in favor of the Municipality of Noveleta: The Court reiterated that the right to appeal is a statutory privilege and must be exercised in the manner and within the period prescribed by law. Since the substituted plaintiffs failed to perfect their appeal from the trial court's decision concerning the Municipality of Noveleta, they were deemed to have waived their right to question that particular portion of the judgment. The appellate court correctly affirmed the trial court's decision in this regard, as it was no longer within its jurisdiction to review a judgment that had already attained finality. The principle of res judicata applies to judgments that have become final, preventing the relitigation of issues already decided.
Main Doctrine
A judgment in favor of a party, which was not appealed by the opposing party, attains finality and becomes immutable, regardless of whether the judgment was correct or not.