Esperas v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a civil case filed by the Heirs of Ponciano Aldas against Victorio Esperas. The Regional Trial Court (RTC) initially ruled in favor of Esperas, dismissing the complaint for lack of merit. This decision was also upheld upon a motion for reconsideration. 2. Procedural History: Following the RTC's dismissal, the Heirs of Ponciano Aldas filed a notice of appeal. Esperas subsequently moved to dismiss this appeal before the RTC for failure to prosecute, which the RTC granted. The Heirs of Ponciano Aldas then filed a petition for certiorari and mandamus with the Court of Appeals (CA), arguing the RTC lacked jurisdiction to dismiss the appeal. The CA Special Eighth Division agreed, nullifying the RTC's dismissal orders and stating such motions should be filed with the CA. Esperas then filed a motion to dismiss the appeal with the CA, which was granted. This dismissal was appealed to the Supreme Court as G.R. No. 101461, but it was dismissed for being filed out of time, leading to finality. Despite this, the Heirs of Ponciano Aldas received a notice from the CA to submit briefs for CA-G.R. CV No. 29581, which Esperas argued was the same case previously dismissed. 3. The Petition: This petition for certiorari under Rule 65 of the Rules of Court seeks to annul the CA Second Division's resolutions denying Esperas' prayer to dismiss the appeal in CA-G.R. CV No. 29581. Esperas argues that the CA Second Division acted without or in excess of jurisdiction, abused its discretion, and violated the principle of res judicata by taking cognizance of an appeal that had already been finally adjudicated. He contends that CA-G.R. CV No. 29581 and the previously dismissed CA-G.R. SP No. 2269 (elevated as G.R. No. 101461) involve the same parties, subject matter, and causes of action, rendering the current appeal moot and academic.
Issue(s)
Whether the Court of Appeals acted without or in excess of its jurisdiction or with grave abuse of discretion when it took cognizance of an appeal that had already been finally adjudicated, thereby violating the principle of res judicata. Whether the Court of Appeals has the power to set aside or nullify a previous decision rendered by another division of the same court. Whether the proceedings before the Court of Appeals' Second Division were valid and not barred by prior judgment. Whether the principle of res judicata applies to the instant case (addressed in Issue 1).
Ruling
The petition is GRANTED. The resolution of the Court of Appeals, Second Division, dated May 13, 1994, denying petitioner's prayer for the dismissal of the ordinary appeal, and its resolution dated April 19, 1995, denying petitioner's motion for reconsideration are REVERSED and SET ASIDE. The Court of Appeals is ordered to dismiss the appeal of private respondents in CA-G.R. CV No. 29581.
Ratio Decidendi
On the issue of whether the Court of Appeals acted without or in excess of its jurisdiction or with grave abuse of discretion when it took cognizance of an appeal that had already been finally adjudicated, thereby violating the principle of res judicata: The Supreme Court agreed with the petitioner that the Court of Appeals' Second Division erred in not dismissing the appeal in CA-G.R. CV No. 29581 on the ground that it was barred by res judicata. The Court found that CA-G.R. SP No. 22695 and CA-G.R. CV No. 29581 involved the same parties, the same facts, and the same issues. The dismissal of the petition for review on certiorari in G.R. No. 101461, which affirmed the Special Eighth Division's resolution granting the motion to dismiss the appeal, rendered the decision of the Regional Trial Court the law of the case. This final adjudication constituted a bar to any re-litigation of the same issues under the principle of res judicata. Therefore, the Second Division's denial of the prayer to dismiss the appeal meant it was effectively reversing a final order of another division of co-equal rank, which constitutes grave abuse of discretion. The appeal in CA-G.R. CV No. 29581 had become moot and academic, as courts will not determine moot questions. The resolution of the Court of Appeals' Special Eighth Division, granting the motion to dismiss, had already terminated the controversy between the parties, especially in light of the Supreme Court's ruling in G.R. No. 101461. On the issue of whether the Court of Appeals has the power to set aside or nullify a previous decision rendered by another division of the same court: The Second Division's denial of the prayer to dismiss the appeal meant it was effectively reversing a final order of another division of co-equal rank, which constitutes grave abuse of discretion. On the issue of whether the proceedings before the Court of Appeals' Second Division were valid and not barred by prior judgment: The dismissal of the petition for review on certiorari in G.R. No. 101461, which affirmed the Special Eighth Division's resolution granting the motion to dismiss the appeal, rendered the decision of the Regional Trial Court the law of the case. This final adjudication constituted a bar to any re-litigation of the same issues under the principle of res judicata. The appeal in CA-G.R. CV No. 29581 had become moot and academic, as courts will not determine moot questions. The resolution of the Court of Appeals' Special Eighth Division, granting the motion to dismiss, had already terminated the controversy between the parties, especially in light of the Supreme Court's ruling in G.R. No. 101461. On the issue of whether the principle of res judicata applies to the instant case (addressed in Issue 1): Addressed in Issue 1.
Main Doctrine
The Court of Appeals commits grave abuse of discretion when it takes cognizance of an appeal that has already been barred by prior judgment, effectively reversing a final adjudication by another division of co-equal rank, as such action would lead to re-litigation of the same issues, parties, and subject matter, violating the principle of res judicata.