Amigo v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners Lolita Amigo and Estelita vda. de Salinas were lessees of a parcel of land in Davao City since 1961. The land was later sold to Juan Bosquit and private respondent Jesus Wee Eng. Bosquit and Wee Eng exchanged a portion of their land with a portion of land owned by the City Government of Davao. Subsequently, Wee Eng became the sole registered owner of the disputed lots. Wee Eng filed an unlawful detainer case against petitioners, which was dismissed by the city court on a technicality. Wee Eng then filed a complaint for recovery of real property and damages, and later amended it to include abatement of nuisance for improvements encroaching on the sidewalk. A commissioner's report indicated that portions of petitioners' houses were on the disputed lot and the road widening. The trial court ruled in favor of Wee Eng, ordering petitioners to vacate the occupied portions, pay monthly rentals, demolish encroaching structures, and pay attorney's fees. Procedural History: Petitioners appealed to the Court of Appeals, but their appeal was dismissed for failure to file an appeal brief. A petition for relief was also denied. Wee Eng moved for execution, which was granted, and a writ of demolition was issued. Petitioners then filed an action with the Court of Appeals to annul the trial court's decision and subsequent writs, alleging lack of jurisdiction. The Court of Appeals granted a temporary restraining order but later dismissed the annulment petition. The Petition: Petitioners filed a petition for review on certiorari with the Supreme Court, challenging the Court of Appeals' decision dismissing their annulment petition. They raised issues concerning the trial court's jurisdiction over the subject matter and their persons, alleged badges of fraud in the land exchange, the effect of the land exchange on their status as lessees, and their right of first refusal under PD 1417.
Issue(s)
Whether the trial court acquired jurisdiction over the subject matter and the person of the petitioners. Whether the final judgment of the trial court can be annulled based on factual arguments regarding fraud in the land exchange or the right of first refusal under P.D. No. 1517.
Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the Court of Appeals. The Court held that the petition should not be used to reopen the entire controversy and that it would only address the issue of jurisdiction. The Court found that the trial court had jurisdiction over the subject matter as the case involved recovery of real property, and petitioners had submitted to the court's jurisdiction over their persons by filing an answer. The Court also noted that the issue of jurisdiction over the person was not seasonably raised.
Ratio Decidendi
On Issue 1: The Court ruled that the trial court possessed jurisdiction over the subject matter and the persons of the petitioners. Jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint; since the suit was for the recovery of real property, it fell within the jurisdiction of the Regional Trial Court (RTC) under Batas Pambansa Blg. 129 (B.P. 129). Regarding jurisdiction over the person, the Court emphasized that this is acquired through the service of summons or voluntary appearance. By filing an answer and an amended answer, petitioners effectively appeared before the court and submitted to its authority, thereby waiving any formal notice requirements. Applying the ruling in La Naval Drug Corporation v. Court of Appeals, the Court held that personal jurisdiction issues must be seasonably pleaded, and it was too late for petitioners to challenge it after a final judgment had been rendered. Therefore, the judgment was not coram non judice. On Issue 2: The Court declined to address the issues of fraud in the land exchange and the 'right of first refusal' under Presidential Decree (P.D.) No. 1517. It held that an action for annulment of judgment is an extraordinary remedy aimed only at judgments that are void for want of jurisdiction or extrinsic fraud. Such a petition should not be used as a stratagem to reopen a controversy that has been settled by a final and executory decision. Because the trial court had jurisdiction, its findings of fact and conclusions of law—even if they were allegedly erroneous—are binding and immutable. The Court stressed that allowing these matters to be litigated anew would make a farce of the judicial process and the doctrine of finality of judgments.
Main Doctrine
A petition to annul a writ of execution and demolition based on a final and executory judgment cannot be used to reopen the entire controversy or litigate matters outside the question of jurisdiction. Jurisdiction over the subject matter is conferred by law and determined by the allegations of the complaint, while jurisdiction over the person is acquired by voluntary appearance or service of summons, which must be seasonably raised.