Nery v. Leyson
REITERATIONFacts
1. The Antecedents: Petitioners claim to be heirs of Mercedes del Rio, who allegedly owned a share in a parcel of land covered by OCT No. RO-0083. They assert that their mother, Mercedes del Rio, was impleaded as a defendant in Civil Case No. R-8646, but she had already died prior to the filing of that case. Consequently, petitioners argue that the decision in Civil Case No. R-8646, which declared TCT No. 19747 in the name of respondents valid and ordered the cancellation of OCT No. RO-0083, does not bind them as they were not parties to the said proceedings and their mother's death was not properly addressed. 2. Procedural History: The respondents, as plaintiffs in Civil Case No. R-8646, obtained a favorable judgment from the Court of First Instance of Cebu, which was later affirmed by the Court of Appeals in CA-G.R. No. 45878-R. This decision became final and executory on April 10, 1976. Despite efforts to execute the judgment, it did not materialize. Subsequently, on January 16, 1991, petitioners filed a new case, Civil Case No. 2379-L, seeking the declaration of nullity of TCT No. 19747 and the judicial proceedings in Civil Case No. R-8646. The Regional Trial Court of Lapu-Lapu City dismissed petitioners' complaint, and the Court of Appeals affirmed this dismissal. 3. The Petition: Petitioners seek review of the Court of Appeals' decision, arguing that the appellate court erred in ruling that their action was barred by the principle of conclusiveness of judgment and that the decision in Civil Case No. R-8646 became final and executory against them. They contend they were deprived of their day in court as they were not properly impleaded or given notice in the original proceedings. The petition is filed under Rule 45 of the Rules of Court, seeking to overturn the appellate court's affirmation of the dismissal of their complaint.
Issue(s)
Whether or not the Court of Appeals erred in ruling that the petitioners’ cause of action was barred by the principle of conclusiveness of judgment under Rule 39, Section 49, Paragraph (c) of the Rules of Court. Whether or not the Court of Appeals erred in ruling that the decision in Civil Case No. R-8646, as affirmed by the Court of Appeals in CA-GR No. 45678-R, became final and executory against herein petitioners, and whether the action for annulment of judgment could prosper.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that while the petitioners were not bound by the decision in Civil Case No. R-8646 due to lack of jurisdiction over them, their action for annulment of judgment was fatally defective because a Regional Trial Court has no jurisdiction to annul a final judgment of a co-equal court; such jurisdiction lies exclusively with the Court of Appeals.
Ratio Decidendi
On the issue of conclusiveness of judgment: The Court found that there was no identity of parties between Civil Case R-8646 and Civil Case 2379-L, as the petitioners were indispensable parties who were not properly impleaded or served summons in the earlier case. The Court clarified that while res judicata does not require absolute identity of parties, substantial identity exists only when the additional party acts in the same capacity or is in privity with the parties in the former action, which was not the case here as co-owners are not parties inter se in relation to the property owned in common. Therefore, the petitioners should not have been bound by the decision in Civil Case No. R-8646 based on res judicata or conclusiveness of judgment. On the issue of annulment of judgment: Despite finding that the petitioners were not bound by the prior judgment, the Court held that their action for annulment of the judgment in Civil Case No. R-8646 could not prosper. This is because the Regional Trial Court (RTC) that heard Civil Case No. 2379-L lacked the jurisdiction to annul a final judgment of a co-equal court. The Court emphasized that Section 9 of BP 129 vests exclusive jurisdiction over actions for annulment of judgments of regional trial courts in the Court of Appeals. Therefore, even if the prior judgment was flawed for lack of jurisdiction over the petitioners, the RTC could not correct it; only the Court of Appeals could entertain such an action.
Main Doctrine
A regional trial court has no authority to annul the final judgment of a co-equal court; jurisdiction over actions for annulment of judgments of regional trial courts lies exclusively with the Court of Appeals.