Ocampo v. Arboleda
REITERATIONFacts
The Antecedents: Private respondents (Andres Arboleda, Ester Arboleda, Cirilo Arboleda) filed Civil Case No. 5013 against petitioners (Luisa Brillante Ocampo, Catalina Ocampo, Roberto Ocampo, Alejandro Brillante) for quieting of title, ejectment, and damages. The private respondents claimed ownership and possession of Lot No. 3720-C, evidenced by Transfer Certificate of Title No. 19916, which they acquired from the heirs of the original owners, Cecilio Arboleda and Hilaria Brillante. Petitioners, who are relatives of the original owners, constructed houses on the land without the plaintiffs' consent. Despite tolerating their presence, petitioners began destroying improvements and asserting ownership in 1966. Amicable settlement attempts failed, leading to the filing of the case. Procedural History: The trial court in Civil Case No. 5013 rendered a decision in favor of the private respondents, declaring them owners, ordering petitioners to vacate, and awarding damages and attorney's fees. Petitioners' motion for reconsideration and subsequent petition for relief from judgment were denied. Petitioners then filed Civil Case No. 5643 for annulment of the judgment in Civil Case No. 5013, reiterating the same grounds. The private respondents filed a motion to dismiss Civil Case No. 5643 on the grounds of lack of jurisdiction and res judicata. The trial court dismissed Civil Case No. 5643, and a motion for reconsideration was denied, leading to the present petition. The Petition: Petitioners contend that the order of default against them in Civil Case No. 5013 was without legal basis and that the dismissal of Civil Case No. 5643 was also without sufficient legal basis, arguing they had a valid cause of action and were denied due process.
Issue(s)
Whether the order of default against the petitioners in Civil Case No. 5013 was without legal and procedural basis. Whether the dismissal of Civil Case No. 5643 was without sufficient procedural and legal basis, considering the petitioners' claim of a valid cause of action and denial of due process.
Ruling
The petition is dismissed for lack of merit. The decision in Civil Case No. 5013 is affirmed, and the dismissal of Civil Case No. 5643 is upheld. The decision in Civil Case No. 5013 is immediately executory.
Ratio Decidendi
On the order of default in Civil Case No. 5013: The Supreme Court found that the petitioners were duly notified of the pre-trial conferences, which were repeatedly postponed at their instance. When the case was called for pre-trial on September 3, 1976, only the plaintiffs appeared despite all defendants having received due notice. Consequently, the defendants were declared in default and allowed to present evidence ex-parte. The Court found that due process was not denied as the petitioners had the opportunity to appear and present their defense but failed to do so. The trial court's explanation that the decision was based on evidence presented during a proper hearing, not solely on the default, further supported the validity of the proceedings. On the dismissal of Civil Case No. 5643: The Court held that the dismissal was justified on two grounds: first, the allegations in the complaint for annulment of judgment did not warrant setting aside the previous decision, as there was no showing of extrinsic fraud, lack of jurisdiction, or a patently void decision. Second, all the elements of res judicata were present. The issues raised in the annulment case were substantially the same as those previously litigated and resolved in the motion for reconsideration and petition for relief in Civil Case No. 5013. The petitioners failed to avail themselves of timely appeals or certiorari, making the decision in Civil Case No. 5013 a settled issue.
Main Doctrine
A petition for annulment of judgment based on grounds already raised in a motion for reconsideration and petition for relief, and which fails to establish extrinsic fraud or lack of jurisdiction, is dismissible on the grounds of res judicata and failure to state a valid cause of action. Due process is not denied when a party, despite due notice, fails to appear for pre-trial and subsequent hearings.