Houdini Ibabao v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute involves two consolidated cases: Civil Case No. V-841, an action for quieting of title, recovery of possession, and damages filed by the heirs of Zosimo Rico (private respondents) against the Ibabao family (petitioners), and Cadastral Case No. N-1 concerning numerous lots, including those subject to Civil Case No. V-841. The Court of First Instance of Romblon initially ruled in favor of the Ibabao family, declaring Pantaleon Ibabao the owner of specific lots and ordering the Ricos to vacate, while adjudicating other lots to the Ricos. This decision became final and executory due to no timely appeal. 2. Procedural History: The private respondents filed a Petition for Relief from Judgment, which was later destroyed by fire and subsequently reconstituted. The trial court dismissed this petition. The private respondents appealed this dismissal to the Intermediate Appellate Court (IAC). Concurrently, the private respondents filed a separate Petition for Annulment of Judgment with the IAC, which was also dismissed. This dismissal was appealed to the Supreme Court (G.R. No. 66141) and was ultimately dismissed by the Supreme Court, rendering it final and executory. Meanwhile, the IAC, in the appeal from the dismissal of the Petition for Relief, ordered the case remanded for reconstitution and retrial, despite the petitioners' motion to dismiss the appeal. The IAC issued several resolutions, including a corrected and re-corrected resolution, enjoining the Regional Trial Court from executing its earlier order and resetting the retrial. The petitioners then filed the present petition before the Supreme Court. 3. The Petition: This is a petition for certiorari, prohibition, and mandamus seeking to set aside the IAC resolutions that ordered the remand of the case for reconstitution and retrial, and to compel the IAC to dismiss the appeal as moot and academic. The petitioners argue that the Supreme Court's prior decision in G.R. No. 66141 (the annulment of judgment case) has already resolved the issues, rendering the appeal from the dismissal of the petition for relief moot and academic due to res judicata. They also question whether the filing of the annulment petition constituted abandonment of the appeal from the dismissal of the relief petition and whether remanding a case for reconstitution and retrial is a matter of discretion.
Issue(s)
Whether or not the appeal from the decision dismissing the Petition for Relief from Judgment had been abandoned by the filing of a separate and independent Petition for Annulment of Judgment. Whether or not the decision in the Petition for Annulment of Judgment had rendered moot and academic the appeal from the decision dismissing the Petition for Relief from Judgment. Whether or not the remanding of a case for reconstitution and retrial is a matter of judicial discretion.
Ruling
The petition is GRANTED. The resolutions of the respondent Intermediate Appellate Court dated May 15, 1984, July 23, 1985, July 26, 1985, and January 10, 1986, are SET ASIDE. The Court of Appeals is ordered to desist from remanding the case for reconstitution and retrial. The respondents’ appeal from the dismissal of their petition for relief from judgment is dismissed for being MOOT and ACADEMIC.
Ratio Decidendi
On the issue of whether the appeal from the decision dismissing the Petition for Relief from Judgment had been abandoned by the filing of a separate and independent Petition for Annulment of Judgment: The Court clarified that the filing of an independent action for annulment of judgment does not automatically result in the abandonment of a petition for relief or an appeal therefrom, unless both actions are predicated on identical grounds. However, the Court reiterated that such actions may be barred by res judicata and the prohibition against multiplicity of suits. In this case, while the actions were pursued separately, their underlying basis and the issues raised were identical, leading to the application of res judicata. On the issue of whether the decision in the Petition for Annulment of Judgment rendered moot and academic the appeal from the dismissal of the Petition for Relief from Judgment: The Court held that the decision in G.R. No. 66141, which affirmed the dismissal of the petition for annulment of judgment, constituted res judicata. For res judicata to apply, there must be a final judgment or order, rendered by a court of competent jurisdiction, on the merits, with identity of parties, subject matter, and causes of action. The Court found that the petition for relief and the petition for annulment involved the same parties, subject matter, and causes of action, seeking to set aside the same trial court decision. Since the Supreme Court had already rendered a final and executory decision on the annulment case, the appeal from the dismissal of the petition for relief became moot and academic. The principle of res judicata prevents the relitigation of the same issues, even if presented in a different form of action. The Court emphasized that "interest republicae ut sit finis litium" (it is to the interest of the public that there be an end to litigation). On the issue of whether the remanding of a case for reconstitution and retrial is a matter of judicial discretion: The Court stated that the remand of cases for reconstitution or retrial is a matter of necessity for the proper disposition of cases, not a matter of discretion. It cannot be denied when circumstances call for it and are within the appellate court's jurisdiction. However, it cannot be ordered where finality of judgment dictates otherwise. The Court found the IAC's order for remand and retrial to be erroneous and dilatory, especially since the case had already undergone reconstitution and trial, and a final judgment had been rendered. The Court stressed that justice delayed is justice denied, and remanding a case unnecessarily would contravene this principle.
Main Doctrine
A prior judgment on the merits, rendered by a court of competent jurisdiction with identity of parties, subject matter, and causes of action, operates as res judicata, rendering subsequent actions on the same issues moot and academic. A petition for relief from judgment is not a substitute for a lost appeal and requires allegations of fraud, accident, mistake, or excusable negligence.