Mercado v. Ubay
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a civil action for partition filed by the petitioners against the private respondents and their siblings. The Court of First Instance of Cavite rendered a judgment in favor of the petitioners, which became final and executory as no appeal was filed by the defendants. 2. Procedural History: Following the finality of the Cavite court's judgment, the defendants, including the private respondents, filed a petition for certiorari and mandamus with the Court of Appeals seeking to annul the writ of execution. This petition was dismissed for lack of merit. Subsequently, the private respondents filed a separate action before the Court of First Instance of Rizal, seeking to annul the final judgment rendered by the Cavite court, alleging lack of authorization for their counsel and lack of knowledge of the prior certiorari proceedings. 3. The Petition: The petitioners, as defendants in the annulment case, filed this petition for certiorari and prohibition under Rule 65 of the Revised Rules of Court. They seek to restrain the respondent judge from proceeding with the annulment case, arguing that the Court of First Instance of Rizal lacked jurisdiction to annul a final and executory judgment rendered by another court of first instance. The core of the petition is whether the Rizal court committed grave abuse of discretion or acted without jurisdiction in denying the motion to dismiss the annulment action, with the petitioners asserting that the issue is one of venue rather than jurisdiction, and that the grounds for annulment were not sufficiently established.
Issue(s)
Whether the Court of First Instance of Rizal committed grave abuse of discretion or acted without jurisdiction in denying the petitioners' motion to dismiss the action for annulment of the final and executory judgment rendered by the CFI of Cavite, considering the grounds for annulment and authority of counsel. Whether venue was properly laid in the CFI of Rizal for an action to annul a judgment rendered by the CFI of Cavite, and the implications for judicial stability and finality of judgments.
Ruling
The petition is GRANTED. The respondent judge of the Court of First Instance of Rizal (now Regional Trial Court) is ORDERED to dismiss Civil Case No. C-2442. The temporary restraining order issued by this Court is hereby made permanent.
Ratio Decidendi
On the jurisdiction to annul a final and executory judgment, grounds for annulment, and authority of counsel: The Court held that under Section 44(a) of the Revised Judiciary Act of 1948, Courts of First Instance had original jurisdiction over civil actions where the subject of litigation is not capable of pecuniary estimation, which includes actions for the annulment of a judgment. Therefore, a Court of First Instance has the authority and jurisdiction to annul a final and executory judgment rendered by another Court of First Instance or another branch thereof. This ruling overturned contrary decisions and was based on cases like Dulap v. Court of Appeals and Gianan v. Imperial. The Court emphasized that the choice of which court to file the annulment action is not left to the parties but is mandated by law to be filed with the Court of First Instance. Even if jurisdiction and venue were disregarded, the Court found no sufficient grounds to justify the annulment of the final judgment. Annulment is only allowed on two grounds: lack of jurisdiction or lack of due process, or if obtained by fraud. The respondents' claim of not being served summons was untenable as they admitted service through a co-defendant who acknowledged receipt, and they subsequently filed an answer and a petition for certiorari through counsel. The Court also noted the presumption of regularity in the sheriff's performance of duties. The Court found the allegation that Atty. Danilo Pine was not authorized to appear on behalf of the respondents to be devoid of merit. An attorney is presumed to be properly authorized, and no written power of attorney is required. The filing of an answer and the appearance of counsel are sufficient to give the respondents standing in court. The Court found it hard to believe that a counsel would vigorously defend a case without authorization, suggesting the annulment suit was a mere attempt to get a second chance after an adverse decision in the certiorari petition. On the venue of the action for annulment and judicial stability: The Court found that venue was improperly laid in the CFI of Rizal. The complaint stated that the respondents resided in Caloocan City and the petitioners resided in Cavite. Since an action for annulment of judgment is a personal action, venue should have been laid in the CFI of Caloocan or CFI of Cavite, at the election of the plaintiff, as per Section 2(b), Rule 4 of the Rules of Court. The respondent judge should have dismissed the action on the ground of improper venue. The Court reiterated the fundamental principle that every litigation must come to an end. Once rights have been adjudicated in a valid final judgment, a litigant should not be granted an unbridled license to relitigate. The prevailing party should not be harassed by subsequent suits, as encouraging endless litigations would be detrimental to the administration of justice, citing Ngo Bun Tiong v. Sayo and Pacquing v. Court of Appeals.
Main Doctrine
A Court of First Instance has jurisdiction to annul a final and executory judgment rendered by another Court of First Instance, but the venue for such action must be properly laid according to the rules on venue for personal actions.