Idang v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Felimon Idang, awardee of a National Housing Authority (NHA) house, leased a portion thereof to private respondent Juan Batinga on a month-to-month basis. Idang filed an action for recovery of possession and damages against Batinga, citing his need for the premises and Batinga's failure to pay rent since April 1984. Procedural History: The Regional Trial Court (RTC) ruled in favor of Idang. However, the Court of Appeals (CA) reversed this, sustaining Batinga's position that Idang was divested of his right to occupy the house due to being an absentee owner, citing an NHA rule. Idang did not appeal this decision. Subsequently, Idang filed an ejectment case, which was dismissed by the Metropolitan Trial Court (MeTC) based on the CA's decision. The RTC affirmed the MeTC's decision, and the CA, upon review, also affirmed the RTC's ruling. The Petition: Idang filed a petition for review on certiorari with the Supreme Court, seeking to overturn the CA's decision. He argued that the prior judgment in the possessory action was void because, due to his counsel's negligence, he was unable to present documents (light and water bills) proving he was not an absentee owner.
Issue(s)
Whether the prior judgment in the possessory action, which declared petitioner divested of his right to occupy the property, is void and can be collaterally attacked in a subsequent ejectment case. Whether petitioner was indeed an absentee owner based on the evidence presented.
Ruling
The Supreme Court denied the petition for review on certiorari for lack of merit, affirming the decision of the Court of Appeals. The Court reconsidered and recalled its resolution giving due course to the petition.
Ratio Decidendi
On the issue of the validity of the prior judgment and collateral attack: The courts below correctly dismissed petitioner's ejectment action based on the principle of res judicata. The prior judgment in the possessory action, which declared petitioner divested of his right to occupy and possess the house, could not be collaterally attacked in the subsequent ejectment case. Petitioner's claim that the prior judgment was void due to his counsel's alleged negligence in presenting evidence was not a valid ground for collateral attack. The proper recourse for petitioner would have been to appeal the decision in the possessory action or to file an action for annulment of judgment, neither of which he pursued. The validity of the decision of the Regional Trial Court in the action for recovery of possession, which was initially in favor of the petitioner, could not be assailed in this manner. The Court of Appeals reversed that decision, holding petitioner to have lost his right to occupy the property on the ground of absenteeism, and this decision became final and executory. On the issue of petitioner being an absentee owner: The Court found no merit in petitioner's argument that he was not an absentee owner. The light and water bills he claimed to have been unable to present were considered by the lower courts but were not given sufficient weight to prove his claim. The Court noted that payment of utility bills does not necessarily negate absenteeism, as an owner could still maintain another dwelling. Furthermore, NHA receipts allegedly not submitted were issued after the decision in the possessory action had become final, rendering them irrelevant to the issue of his status at the time of the census. Therefore, the appellate court's finding that petitioner was an absentee owner, based on the NHA rule, was sustained.
Main Doctrine
A prior judgment, even if allegedly erroneous, cannot be collaterally attacked in a subsequent proceeding; the proper remedy is to appeal the decision or file an action for annulment of judgment.