Spouses Mesina v. Meer
NEW DOCTRINEFacts
The Antecedents: Respondent Humberto Meer discovered that his land title had been cancelled and a new one issued to spouses Sergio and Lerma Bunquin, who claimed to have acquired the property via a deed of sale purportedly executed by Meer. Meer filed a case to cancel the Bunquins' title, and a notice of lis pendens was annotated. Subsequently, the property was conveyed to petitioners, spouses Michaelangelo and Grace Mesina, who were then impleaded as additional defendants. The Bunquins were declared in default, but the Mesinas actively participated in the proceedings. Procedural History: The Metropolitan Trial Court ruled that the sale to the Bunquins was fraudulent but found the Mesinas to be buyers in good faith, dismissing the complaint against them. Respondent Meer appealed to the Regional Trial Court, which reversed the MeTC's decision, finding the Mesinas not to be good faith purchasers due to the belated registration of their deed of sale after the lis pendens annotation. The RTC ordered the cancellation of both the Bunquins' and Mesinas' titles. The Court of Appeals affirmed the RTC's ruling. The Mesinas then filed a Petition for Relief from Judgment with the Court of Appeals, alleging extrinsic fraud, mistake, and excusable negligence, which the Court of Appeals denied. The Mesinas' motion for reconsideration was also denied. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' resolutions that denied their Petition for Relief from Judgment. The primary issue raised is the availability of a Petition for Relief under Rule 38 as a remedy against a judgment of the Court of Appeals in its appellate capacity. If available, petitioners sought a ruling on whether their grounds were sufficient to grant the petition, arguing that extrinsic fraud, mistake, and excusable negligence prevented them from presenting their case and appealing within the prescribed period, and that they possessed a good and substantial defense.
Issue(s)
Whether a Petition for Relief from Judgment under Rule 38 of the Rules of Court is available as a remedy against a judgment of the Court of Appeals in the exercise of its appellate jurisdiction. If the remedy is available, whether the grounds relied upon by the petitioners (extrinsic fraud, mistake, and excusable negligence) were sufficient to warrant relief.
Ruling
The petition is denied for lack of merit, and the assailed Resolutions of the Court of Appeals are affirmed.
Ratio Decidendi
On the availability of a Petition for Relief from Judgment against a Court of Appeals judgment in its appellate jurisdiction: The Court held that a Petition for Relief from Judgment under Rule 38 is an equitable remedy allowed only under exceptional circumstances and must be filed with the same court that rendered the judgment or order sought to be set aside. The 1997 Revised Rules of Civil Procedure, while expanding the scope to include "any court," refers only to Metropolitan/Municipal and Regional Trial Courts, not appellate courts. The Court emphasized that the procedures in the Court of Appeals and the Supreme Court are governed by separate provisions, and neither the Rules of Court nor the Revised Internal Rules of the Court of Appeals allow for a petition for relief from judgment in the Court of Appeals. Therefore, the remedy was not available to the petitioners against the CA's resolution. On the sufficiency of the grounds for relief, assuming arguendo its availability: Even if the remedy were available, the Court found the petitioners' grounds insufficient. The alleged extrinsic fraud should have been raised in the Metropolitan Trial Court (MeTC), where the petitioners actively participated and even prevailed initially. They did not raise this issue before the Regional Trial Court (RTC) or the Court of Appeals (CA). The Court stated that it would not allow petitioners to benefit from their own negligence by invoking equity. Regarding the claim of mistake and excusable negligence due to counsel's delay in producing documents, the Court reiterated that relief will not be granted if the loss of the remedy at law was due to the party's own negligence or a mistaken mode of procedure. While acknowledging that in exceptional cases, palpable mistakes of counsel amounting to gross negligence may warrant relief, the petitioners had already squandered various opportunities throughout the proceedings. The Court concluded that public interest demands an end to litigation, and reopening a case that has attained finality would only delay the administration of justice.
Main Doctrine
A Petition for Relief from Judgment under Rule 38 of the Rules of Court is an equitable remedy available only under exceptional circumstances and must be filed with the same court that rendered the judgment or order sought to be set aside. It is not available as a remedy against a judgment of the Court of Appeals in the exercise of its appellate jurisdiction, and the loss of the remedy at law due to one's own negligence or a mistaken mode of procedure bars its grant.