Antonio v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioners were lessees of an apartment building in Caloocan City. The property was foreclosed by the Government Service Insurance System (GSIS) and subsequently sold at a public bidding to the private respondent. The petitioners, believing they had priority to purchase the property as tenants, did not participate in the bidding. After the sale was approved and a conditional deed of sale executed, the GSIS advised the petitioners to pay rent and arrearages to the private respondent. The petitioners failed to do so, leading the private respondent to file an ejectment case. 2. Procedural History: The Metropolitan Trial Court ruled in favor of the private respondent in the ejectment case, ordering the petitioners to vacate and pay damages. The petitioners appealed to the Regional Trial Court, which affirmed the lower court's decision. Subsequently, the petitioners filed a petition for review on certiorari with the Court of Appeals, which dismissed their petition on December 5, 1986. An entry of judgment was issued on February 3, 1987, certifying that the decision became final and executory as of January 22, 1987, and the records were remanded to the Regional Trial Court. On March 10, 1987, the Court of Appeals denied the petitioners' motion for reconsideration, which was filed beyond the reglementary period. The Regional Trial Court subsequently issued a writ of execution on March 6, 1987. 3. The Petition: The petitioners filed a petition for certiorari and mandamus with the Supreme Court, seeking to annul the Court of Appeals' Resolution of March 10, 1987, which denied their motion for reconsideration, and to restrain the Regional Trial Court from implementing its Order for a writ of execution. They argued that the denial of their motion for reconsideration deprived them of due process, as their counsel had allegedly abandoned them and migrated abroad without notice. The Supreme Court, however, found that the motion for reconsideration was filed out of time and that the negligence of counsel is binding on the client. The Court also noted that the petitioners' counsel of record was a law firm, not an individual attorney, and that the issue raised in the motion for reconsideration regarding the pendency of an annulment case was not a bar to the ejectment proceedings.
Issue(s)
Whether the Court of Appeals erred in denying the admission of the petitioners' motion for reconsideration, and whether the petitioners were deprived of due process of law due to the alleged abandonment by their counsel. Whether the pendency of an annulment case of the award in public auction is prejudicial to an ejectment suit warranting suspension of the latter.
Ruling
The petition is dismissed for lack of merit. The Resolution of the Court of Appeals denying the admission of the motion for reconsideration is affirmed. The order of the Regional Trial Court for the issuance of a writ of execution is valid and cannot be stayed.
Ratio Decidendi
On the denial of the motion for reconsideration and due process/alleged abandonment by counsel: The Supreme Court affirmed the Court of Appeals' denial of the motion for reconsideration. It is a well-settled principle that after the lapse of fifteen (15) days from notice of judgment, the same becomes final, and the appellate court loses jurisdiction over the case. The subsequent filing of a motion for reconsideration cannot disturb the finality of the judgment nor restore jurisdiction that has already been lost. The Court emphasized that a decision rendered anew, notwithstanding the finality of the original one, is null and void. In this case, the messenger received a copy of the decision on January 6, 1987, making the judgment final and executory on January 22, 1987. Therefore, the motion for reconsideration filed on February 23, 1987, could not be acted upon on the merits and was properly noted and denied by the Court of Appeals. The Court reiterated the rule that a client is bound by the negligence or failings of counsel, and it is the duty of an attorney to arrange matters so that communications sent by mail reach him promptly. The claim of abandonment by Atty. Funelas was found to be not excusable, especially since the counsel of record was the law office of Funelas Perez and Associates, not Atty. Funelas alone. The subsequent affidavit attempting to contradict this was deemed to have no evidentiary value as it was filed after the questioned resolution was promulgated. The Supreme Court found the negligence attributed to the petitioners' counsel, Atty. Funelas, to be inexcusable. The records clearly showed that the counsel of record was the law office of Funelas Perez and Associates, and Atty. Funelas signed documents as its representative. The Court noted that the respondent Court of Appeals made the same observation. The petitioners' attempt to prove that Atty. Funelas was the sole member of the firm and that it was dissolved was unavailing, as the affidavit supporting this claim was executed and submitted after the questioned resolution was promulgated, rendering it a mere afterthought with no evidentiary value. The Court reiterated the established doctrine that when a party appears by an attorney, all notices must be given to the attorney, not the client, and the client is bound by the attorney's negligence or failings. The attorney must ensure prompt receipt of judicial notices. On the pendency of the annulment case: The Supreme Court upheld the Court of Appeals' ruling that the pendency of an action for title or annulment of title does not bar an ejectment case. The Court cited established jurisprudence holding that an action for ownership or annulment of title is not a bar to an action for forcible entry and detainer. The fundamental distinction lies in the issues: ejectment cases concern possession, while annulment cases concern ownership. Therefore, an ejectment case can proceed independently of an annulment case, unless the question of possession is so intertwined with ownership that possession cannot be resolved without resolving ownership, which was not the situation in this case. The order of the RTC for the issuance of a writ of execution was justified because the decision in the ejectment case had already become final and executory, and its implementation could not be stayed.
Main Doctrine
A motion for reconsideration filed beyond the reglementary period, after a judgment has become final and executory and the records remanded to the lower court, cannot be acted upon on the merits as the appellate court has lost jurisdiction over the case. The client is bound by the negligence or failings of counsel.