Salera v. A-1 Investors, Inc.
REITERATIONFacts
The Antecedents: Teodora Salera obtained a P50,000.00 loan from A-1 Investors, Inc., which remained unpaid. A-1 Investors, Inc. filed a collection case against Teodora and her husband, Saturnino Salera, Sr. Summons was received by their son, Samuel, who did not sign for it, and Saturnino, Sr. claimed he was in Bohol from 1993-1997, running for mayor, and did not receive the summons. Consequently, they were declared in default, and a decision was rendered ordering them to pay the loan with interest, liquidated damages, and attorney's fees. A copy of the decision was sent to their Cebu address and received by Joel Ariño. The spouses did not appeal, and the decision became final and executory. Sarah Salera, their daughter, received a Writ of Execution and Notice of Levy on their property but did not inform her parents immediately. Saturnino, Sr. learned of a Notice to Parties of Public Auction for their property and filed a complaint for "Injunction with Damages" to prevent the sale, alleging lack of due process and that the property was his exclusive property and exempt as a family home. The RTC issued a TRO and preliminary injunction. Saturnino, Sr. died, and his children, the petitioners, substituted him. Procedural History: The respondent filed motions for summary judgment and to quash the injunction, which were denied by the RTC. The respondent then filed a Petition for Certiorari and Prohibition with the Court of Appeals. The Court of Appeals granted the petition, prohibiting the RTC of Cebu from further proceeding with the injunction case, holding that it was a mere attempt to substitute for a lost appeal and that the RTC lacked jurisdiction. The motion for reconsideration was denied. The Petition: Petitioners seek to annul the Court of Appeals' decision, arguing that RTCs have jurisdiction over injunction cases, that the respondent is estopped from questioning jurisdiction, and that their complaint should have been treated as a petition to annul the Metropolitan Trial Court's decision.
Issue(s)
Whether the Regional Trial Court had jurisdiction over the injunction case, considering it as an indirect attack on a final and executory judgment. Whether the respondent is estopped from raising the issue of lack of jurisdiction, given their participation in the proceedings; and whether the complaint should be treated as an action for annulment of judgment, and if so, whether the RTC of Cebu had jurisdiction. Whether the attempt to enjoin the execution of the final and executory Metropolitan Trial Court decision was permissible.
Ruling
The petition is denied. The Court of Appeals' decision and resolution are affirmed. The preliminary injunction issued by the RTC of Cebu is lifted, and said court is prohibited from further proceeding with Civil Case No. CEB-20550.
Ratio Decidendi
On the issue of jurisdiction over injunction cases: While Regional Trial Courts (RTCs) generally have jurisdiction over injunction cases, the nature of the injunction sought in this case was an indirect attack on a final and executory judgment. The petitioners sought to permanently enjoin the public auction of property levied pursuant to a writ of execution. This action, by its very nature, sought to annul the decision in Civil Case No. 15996, which was the basis for the writ of execution. Therefore, the proper remedy was not an action for injunction but an action for annulment of judgment under Rule 47 of the Rules of Civil Procedure. The RTC of Cebu, in entertaining the injunction case, was effectively being asked to pass upon the validity of a judgment from another court, which it could not do directly through an injunction suit. On the issue of estoppel and annulment of judgment: The Supreme Court found that the respondent was not estopped from assailing the jurisdiction of the RTC of Cebu because they consistently questioned the jurisdiction. The complaint filed in the RTC of Cebu was not an action for annulment of judgment because it was captioned "Injunction with Damages" and did not pray for the annulment of the decision in Civil Case No. 15996, failing to meet the requirements of Rule 47. Even assuming arguendo that the action was for annulment of judgment, the RTC of Cebu did not have the proper jurisdiction because Section 10, Rule 47 states that an action to annul a judgment of a Municipal Trial Court shall be filed in the Regional Trial Court having jurisdiction over the former. Since the original decision was rendered by the Metropolitan Trial Court of Quezon City, the action for annulment should have been filed in the RTC of Quezon City, not Cebu. On the finality of the MeTC decision: The Supreme Court emphasized that the decision of the Metropolitan Trial Court in Civil Case No. 15996 had become final and executory. The petitioners' attempt to enjoin the execution of this judgment through an injunction case, which was essentially an indirect attack on the final judgment, was impermissible. The Court stressed that it could not allow such "wily ways" to make a mockery of the justice system and render a final judgment empty. The petitioners should have availed of the proper remedies, such as an appeal or a petition for annulment of judgment filed in the correct court.
Main Doctrine
A complaint for injunction cannot be used to substitute for a lost appeal or to annul a final and executory judgment. The proper remedy for challenging a judgment for lack of jurisdiction or extrinsic fraud, after ordinary remedies are no longer available, is an action for annulment of judgment under Rule 47 of the Rules of Civil Procedure. Furthermore, an action to annul a judgment of a Municipal Trial Court must be filed in the Regional Trial Court having jurisdiction over the former.