Ruiz v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Dr. Hector S. Ruiz was the registered owner of Magalawa Island. He appointed respondent Rodolfo V. Siojo as his exclusive agent to sell the property for P3.5 million with a 5% commission. Subsequently, Ruiz entered into an agreement with Francisco Joaquin to develop the island, but this did not materialize. Ruiz then executed a Deed of Absolute Sale in favor of Siojo, purportedly to hinder Joaquin and protect an advance payment, and for humanitarian reasons. Later, Siojo and respondent Angel Al. Caluntad allegedly convinced Ruiz to file a replevin suit against Ruiz himself, which resulted in a judgment in their favor, leading to the loss of the Transfer Certificate of Title (TCT) No. 25102. Ruiz later sold the property to Mr. Christian M. Prolin and agreed to return P300,000.00 to Siojo, executing a Deed of Reconveyance. Procedural History: Dr. Hector S. Ruiz filed a complaint for Annulment of Decision, Documents, Surrender of Owner's Duplicate of Title, Damages with Preliminary Injunction before the Court of Appeals (CA-G.R. No. 15411), seeking to annul a judgment obtained in Civil Case No. 37590 before the Regional Trial Court of Quezon City. The Court of Appeals initially admitted Ruiz's amended petition but later set aside its resolution and dismissed the petition due to late filing of the amended petition and failure to file an opposition or comment on the respondents' motion for reconsideration. Ruiz's motion for reconsideration was also denied. This led to the present petition for review on certiorari before the Supreme Court. The Petition: Petitioner Ruiz seeks to annul the Resolutions of the Court of Appeals dated February 28, 1990, and May 8, 1990, which dismissed his petition for annulment of decision. He argues that the Court of Appeals erred in dismissing his case on mere technical grounds, specifically the one-day late filing of his amended petition, and contends that his statement in an Urgent Motion for Extension of Time to Comment should have been considered as his comment. He also asserts that the inclusion of Atty. Jambora as a party-respondent was not intended to delay the case. The petition was given due course, and a notice of the petitioner's death was noted, with his heirs substituted.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition on technical grounds, specifically the late filing of the amended petition and the failure to file a comment on the motion for reconsideration. Whether the statement in the petitioner's Urgent Motion for Extension of Time to Comment could be considered as compliance with the order to file an opposition or comment. Whether the inclusion of Atty. Jambora as a party-respondent was proper. Whether the judgment sought to be annulled was void for want of jurisdiction or lack of due process, or obtained by extrinsic fraud.
Ruling
The petition is DENIED for lack of merit. The Resolutions of the Court of Appeals dated February 28, 1990, and May 8, 1990, are AFFIRMED.
Ratio Decidendi
On the dismissal by the Court of Appeals on technical grounds: The Court held that while it is a settled principle that litigations should be decided on their merits and not on technicalities, a careful perusal of the records showed that even if technicalities were disregarded, no sufficient grounds could be found to grant the petition. The Court of Appeals' dismissal was based on the late filing of the amended petition and the petitioner's failure to file an opposition or comment on the respondents' motion for reconsideration despite being required to do so. The Court found these grounds sufficient for dismissal. On the petitioner's statement as a comment: The Court found that the petitioner's statement in his Urgent Motion for Extension of Time to Comment, invoking the principle of res ipsa loquitur and submitting the incident for resolution, was not a sufficient comment or opposition to the respondents' motion for reconsideration. The Court required a specific comment or opposition, and the petitioner's submission did not meet this requirement, thus justifying the Court of Appeals' finding of failure to comply. On the inclusion of Atty. Jambora: The Court did not directly rule on the propriety of including Atty. Jambora as a party-respondent in the context of the petition before the Supreme Court. However, the Court of Appeals' resolution dismissing the petition was based on other grounds, and the Supreme Court affirmed this dismissal. The petitioner's argument that Jambora's inclusion was for completeness was not given weight in light of the other procedural infirmities. On the grounds for annulment of judgment: The Court reiterated that a judgment can be annulled only on two grounds: (a) the judgment is void for want of jurisdiction or lack of due process of law; or (b) it has been obtained by fraud. Furthermore, an action to annul a final judgment on the ground of fraud will lie only if the fraud is extrinsic or collateral, meaning it prevented a party from having a trial or from presenting all of his case. The records showed that the petitioner received summons, as evidenced by the sheriff's return, and was represented by counsel, Atty. H.A. Jambora, who was consistently furnished copies of court orders and the decision. Notice to counsel is notice to the client. Therefore, the petitioner could not allege lack of knowledge or opportunity to present his case. There was also no allegation of fraud, either intrinsic or extrinsic, that would warrant annulment.
Main Doctrine
A judgment can be annulled only on two grounds: (a) the judgment is void for want of jurisdiction or lack of due process of law; or (b) it has been obtained by fraud. An action to annul a final judgment on the ground of fraud will lie only if the fraud is extrinsic or collateral in character, meaning it has prevented a party from having a trial or from presenting all of his case to the court.