Santana-Cruz v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, heirs of the late Valeriana Marilao, filed a Complaint for Revival/Execution of Judgment After Lapse of Five Years against petitioner and Ma. Paz S. Concepcion. The judgment sought to be revived was rendered on September 30, 1964, by the Court of First Instance of Rizal, ordering the reconveyance of certain lots upon payment by the plaintiffs and execution of the necessary deed of reconveyance. This decision was affirmed in toto by the Court of Appeals on December 5, 1979. Procedural History: On May 7, 1993, petitioner filed an Omnibus Motion to dismiss the complaint. The Regional Trial Court (RTC) denied the motion and ordered the issuance of an alias writ of execution. The RTC subsequently modified its order to direct the Register of Deeds to cancel the existing titles and issue new ones in the name of the private respondents. Petitioner filed a Petition for Certiorari and Prohibition with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. On October 12, 1994, the CA reversed the RTC's orders, declared the alias writ of execution void, and dismissed the complaint for revival/execution of judgment on the ground of prescription. Private respondents filed motions for reconsideration through different counsels. On February 9, 1995, the CA reconsidered its October 12, 1994 decision, granting the motion for reconsideration filed by Atty. Raul A. Mora, and held that the complaint had not prescribed, setting aside its previous decision. On April 21, 1995, the CA denied petitioner's motion for a special order questioning its jurisdiction. The Petition: Petitioner elevated the case to the Supreme Court, arguing that the CA lost jurisdiction when private respondents perfected their appeal to the Supreme Court, and that the CA erred in acting on a motion for reconsideration after an appeal was perfected.
Issue(s)
Whether the Court of Appeals lost jurisdiction over the case when private respondents filed a motion for extension of time to file a petition for review with the Supreme Court. Whether the Court of Appeals erred in acting on the motion for reconsideration filed by private respondents through Atty. Raul A. Mora after private respondents had filed a motion for extension of time to file a petition for review with the Supreme Court. Whether the complaint for revival/execution of judgment had prescribed. Whether the private respondents' failure to implead indispensable parties in the original reconveyance case affects the execution of the judgment.
Ruling
The Supreme Court set aside the Amended Decision of the Court of Appeals dated February 9, 1995, and reinstated its Decision dated October 12, 1994. The Court ruled that the complaint for revival/execution of judgment had prescribed.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that the Court of Appeals did not lose jurisdiction when private respondents filed a motion for extension of time to file a petition for review with the Supreme Court. The Court clarified that the motion for reconsideration filed by Atty. Raul A. Mora with the CA was seasonably filed and was the counsel of record for the private respondents. The Court noted that the filing of the motion for extension of time with the Supreme Court by Atty. Mora occurred after the CA had clarified its earlier resolution, and that Atty. Mora subsequently withdrew his action before the Supreme Court. Therefore, no appeal was considered perfected by the private respondents with the Supreme Court when the CA issued the questioned resolutions, thus the CA retained jurisdiction. On the Court of Appeals acting on the motion for reconsideration: The Court found that the Court of Appeals did not err in acting on the motion for reconsideration filed by Atty. Raul A. Mora, who was the counsel of record for the private respondents. The Court emphasized that the motion filed by Atty. Julian S. Yap was deemed a mere scrap of paper as there was no valid substitution of counsel. Consequently, the CA's Resolution dated December 15, 1994, which denied Atty. Yap's motion, and its subsequent Resolution dated December 22, 1994, were declared null and void. The resolution of the Supreme Court on the petition for review filed by Atty. Yap was also deemed a nullity. The Court found that the CA should have acted only on the motion for reconsideration filed by Atty. Mora, and the inadvertence and delay in its processing should not prejudice the private respondents. On the prescription of the complaint for revival/execution of judgment: The Court ruled that the complaint for revival/execution of judgment had prescribed. The judgment became final and executory on December 23, 1979. The complaint for revival/execution was filed thirteen (13) years later. The Court reiterated that a judgment may be executed on motion within five (5) years from its entry or from when it became final and executory. Thereafter, it may be enforced by an independent civil action within ten (10) years from the time it became final. Absent any finding of delay caused by the petitioner, the thirteen-year delay rendered the complaint prescribed. On the failure to implead indispensable parties: The Court found that the private respondents' failure to implead indispensable parties (the third-party vendees of the lots) in the original reconveyance case was the reason why the judgment could not be executed. The private respondents were aware during the pre-trial that the lots had been sold to third parties, yet they failed to amend their complaint to include these buyers. Without these indispensable parties, the judgment ordering reconveyance was not binding on them, and therefore, private respondents could not impute delay to the petitioner for the inability to reconvey the lots. The Court distinguished this case from National Power Corporation vs. Court of Appeals, stating that the delay in that case was caused by the petitioner, whereas in this case, the delay was attributable to the private respondents' own procedural failure.
Main Doctrine
A complaint for revival/execution of judgment filed thirteen (13) years after the decision became final and executory has long prescribed, absent any finding of delay caused by the petitioner in the execution of the judgment. The delay in the execution of a judgment cannot be attributed to the petitioner when the private respondents themselves failed to implead indispensable parties, thereby rendering the judgment incapable of valid execution.