Lapulapu Development & Housing Corp. v. Risos
REITERATIONFacts
The Antecedents: Lapulapu Development & Housing Corporation (LLDHC) entered into a Project and Loan Agreement with the Government Service Insurance System (GSIS) for the development of 423,177 square meters of land. LLDHC failed to develop the properties and pay the loan, leading GSIS to foreclose the mortgaged properties and acquire them at auction. Subsequently, GSIS executed a Deed of Conditional Sale over the properties in favor of Group Management Corporation (GMC). Procedural History: LLDHC filed a complaint for Annulment of Foreclosure against GSIS. Separately, GMC filed a complaint for Specific Performance with Damages against GSIS to compel the execution of a Final Deed of Absolute Sale. LLDHC intervened in GMC's case, filing a Motion to Dismiss which was denied. The Regional Trial Court (RTC) of Lapulapu City, Branch 27, presided over by Judge Teodoro K. Risos, rendered judgment in favor of GMC, ordering GSIS to execute the deed of sale and pay damages, and dismissing LLDHC's complaint-in-intervention. Both LLDHC and GSIS appealed, but their appeals were dismissed. LLDHC then filed a Petition for Annulment of Judgment before the Court of Appeals, which was also dismissed for failure to show lack of jurisdiction. This dismissal became final and executory. The Petition: LLDHC filed the instant petition for certiorari with preliminary injunction before the Supreme Court, seeking to annul the February 24, 1992 Decision of the RTC, which LLDHC alleged was a reproduction of its dismissed petition for annulment of judgment before the Court of Appeals.
Issue(s)
Whether the Supreme Court has jurisdiction to entertain a petition for certiorari that is essentially a petition for annulment of judgment of a Regional Trial Court. Whether the RTC decision in Civil Case No. 2203-L is void for want of jurisdiction or lack of due process. Whether the RTC decision was obtained by extrinsic fraud. Whether the petition for certiorari was filed within a reasonable period of time.
Ruling
The petition is dismissed. The Supreme Court held that it has no jurisdiction to entertain a petition that is essentially for the annulment of a Regional Trial Court's judgment, as such jurisdiction belongs to the Court of Appeals. Furthermore, even if treated as a petition for certiorari, it was filed beyond the reasonable period prescribed by law and jurisprudence.
Ratio Decidendi
On the jurisdiction of the Supreme Court: The Court reiterated that under Section 9(2) of Batas Pambansa Blg. 129, the Court of Appeals has exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts. The instant petition, despite being denominated as one for certiorari, was found to be a mere reproduction of a prior petition for annulment of judgment filed before the Court of Appeals, which had already become final and executory. Therefore, the Supreme Court correctly determined that it lacked the original jurisdiction to entertain such a petition. On jurisdiction and due process: The Court affirmed the ruling of the Court of Appeals that the RTC had jurisdiction over both the subject matter and the parties in Civil Case No. 2203-L. The action for specific performance with damages falls within the exclusive original jurisdiction of Regional Trial Courts. Furthermore, LLDHC participated in the proceedings as an intervenor, filing a motion to dismiss and actively participating in the full-blown trial, thus negating any claim of lack of due process. On extrinsic fraud: The Court clarified that for fraud to be a basis for annulment of judgment, it must be extrinsic or collateral, meaning it prevented the party from fully presenting its case. The petitioner failed to demonstrate any such extrinsic fraud committed by the prevailing party (GMC). The dismissal of LLDHC's complaint-in-intervention was based on the merits after due hearing, not on any impediment to ventilate its case. On timeliness of the petition: The Court emphasized that even if the petition were treated as one for certiorari under Rule 65, it was filed beyond the reasonable period of three months from receipt of the decision. The decision sought to be annulled was rendered on February 24, 1992, and received by the petitioner on March 3, 1992. The instant petition was filed on February 2, 1995, nearly three years later, rendering it stale and dismissible on procedural grounds.
Main Doctrine
A petition for certiorari under Rule 65, which seeks to annul a judgment of a Regional Trial Court, must be filed within a reasonable period, generally within three months from receipt of the decision, and jurisdiction over such actions for annulment of judgment primarily lies with the Court of Appeals.