Santos v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a lease agreement for a parcel of land with improvements. Yan Chuan, doing business as Standard Food Products, leased the property from Victorio Santos in May 1973 for three years, with a renewal for another three years in April 1976. On February 8, 1978, Santos sold the leased property to Victor Reyes without Yan Chuan's knowledge. Upon the lease's expiration in March 1979, Yan Chuan offered to buy the property, and an agreement was reached for monthly rent of P1,200 until a final selling price could be determined. Yan Chuan paid rent for April and May 1979, but Santos subsequently refused to accept further payments, compelling Yan Chuan to file a Petition for Consignation. 2. Procedural History: Yan Chuan filed a Petition for Consignation in October 1979. Santos responded with an Answer and Counterclaim for ejectment, alleging the lease had expired and Yan Chuan refused to vacate. Yan Chuan's subsequent petition for certiorari regarding the denial of his motion to strike Santos's counterclaim was dismissed by the Court of First Instance (CFI). Meanwhile, the City Court of Manila, proceeding ex-parte due to Yan Chuan's non-appearance at hearings, rendered a decision on December 10, 1980, ordering Yan Chuan to vacate and pay monthly compensation. Yan Chuan's appeal of the CFI's dismissal was itself dismissed by the Court of Appeals (CA) in May 1981. However, Yan Chuan filed a Petition for Relief with the CFI, which was initially dismissed but later given due course as a Second Petition for Relief. The CFI granted a preliminary injunction against enforcing the City Court's judgment, finding a potential violation of due process due to lack of notice. Santos's motion for reconsideration was denied, and the CFI admitted a Third Petition for Relief from Yan Chuan. This led Santos to file a Petition for Certiorari with the CA. 3. The Petition: This petition for review on certiorari seeks to overturn the Court of Appeals' decision promulgated on December 29, 1981, which denied due course and dismissed Yan Chuan's petition, lifting the temporary restraining order. The petitioners argue that the CA gravely abused its discretion in upholding the CFI's jurisdiction to admit Yan Chuan's Third Petition for Relief, contending it was filed beyond the reglementary period prescribed by Section 3, Rule 38 of the Revised Rules of Court. The Supreme Court found merit in this argument, noting that Yan Chuan received the City Court's decision on January 23, 1981, and filed his Petition for Relief on April 23, 1981, exceeding the 60-day period. The Court concluded that the CFI acted without jurisdiction and committed grave abuse of discretion in treating the petition as an annulment of judgment and declaring the trial court's decision void for lack of due process, as the evidence did not sufficiently prove denial of notice.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion in upholding the jurisdiction of the Court of First Instance to admit the private respondent's Third Petition for Relief, which was filed beyond the reglementary period. Whether the City Court's decision dated December 10, 1980, is void for alleged violation of due process due to lack of notice of hearing. Whether the alleged concealment of the sale of the leased property to Victor Reyes constitutes extrinsic fraud warranting annulment of the City Court's decision; and whether the sale of the property was relevant to the ejectment case.
Ruling
The petition is GRANTED. The decision of the Court of Appeals is SET ASIDE, and the decision dated December 10, 1980, of the City Court of Manila is REINSTATED.
Ratio Decidendi
On the timeliness of the Petition for Relief and the jurisdiction of the CFI: The Court held that Section 3, Rule 38 of the Revised Rules of Court mandates that a petition for relief from judgment must be filed within sixty (60) days after the petitioner learns of the judgment and not more than six (6) months after the judgment was entered. In this case, private respondent received the City Court's decision on January 23, 1981, but filed his Petition for Relief on April 23, 1981, which is beyond the sixty-day period. Therefore, the then Court of First Instance acted without jurisdiction when it admitted the petition and committed grave abuse of discretion by treating it as a complaint for annulment of judgment. The Court emphasized that the mandatory period for filing a petition for relief is jurisdictional. On the alleged denial of due process: The Court found that the records did not support the appellate court's findings of denial of due process. While the petitioner initially failed to attach proof of service of the notice of hearing for November 18, 1980, the Court invoked the presumption of regularity in the performance of official duties by court officers. The burden was on the private respondent to prove that the notice was not sent, which he failed to discharge. The evidence on record showed that private respondent was duly notified. The fact that the ejectment case proceeded while a certiorari case was pending with the appellate court did not violate due process, as private respondent was notified of the proceedings and no restraining order was issued to halt the ejectment case. On the claim of extrinsic fraud and the relevance of the sale of the property: The Court reiterated that a judgment can only be annulled on grounds of lack of jurisdiction, lack of due process, or extrinsic fraud. Extrinsic fraud refers to fraudulent acts outside the trial that prevent a party from fully presenting their case. The Court found no such extrinsic fraud. Private respondent was duly notified of the hearing but chose not to appear. The alleged concealment of the sale of the leased property to Victor Reyes did not constitute extrinsic fraud because this fact could have been presented during the ejectment hearing, and private respondent was not prevented from doing so. Moreover, the issue of ownership is not relevant in an ejectment case, which concerns only physical possession. The Court clarified that the sale of the leased property to Victor Reyes, even if not disclosed to the private respondent, was not material to the ejectment case. The issue in ejectment proceedings is solely the physical possession of the property, not the ownership thereof. Therefore, the petitioner's failure to disclose the sale did not vitiate the proceedings in the trial court and did not provide a valid ground to annul the decision. Given that the private respondent's Petition for Relief was filed out of time and thus the CFI acted without jurisdiction, and that no extrinsic fraud or denial of due process was established, the Court concluded that the City Court's decision ordering ejectment and compensation was valid and should be reinstated. The CA's decision, which upheld the CFI's erroneous assumption of jurisdiction, was therefore set aside.
Main Doctrine
A petition for relief from judgment filed beyond the reglementary period of sixty (60) days from knowledge of the judgment, and not more than six (6) months after the judgment was entered, is void for lack of jurisdiction. The Court of First Instance acted without jurisdiction and committed grave abuse of discretion in admitting such a petition and treating it as a complaint for annulment of judgment. Furthermore, the presumption of regularity in the performance of official duties by court officers in sending notices of hearing prevails in the absence of convincing proof to the contrary, and the burden of proof rests on the party alleging lack of notice.