Villareal Manipor v. Spouses Ricafort
REITERATIONFacts
The Antecedents: Respondents Spouses Pablo and Antonia Ricafort filed an action for annulment of Transfer Certificate of Title (TCT) No. 199241, covering a 229-square meter lot in Makati City, registered in the names of spouses Renato and Teresita Villareal. Respondents claimed co-ownership of the property with Abelardo Villareal, Renato's father, based on an agreement where Abelardo recognized their ownership of one-half of the lot. They alleged that Abelardo obtained OCT No. 3913 without their knowledge and consent, and after his death, Renato and Teresita transferred the title to their names. Procedural History: The parties entered into a compromise settlement, approved by the Regional Trial Court (RTC) on July 30, 1999. Renato and Teresita admitted the agreement and agreed to physically divide the lot, with the back portion going to respondents, and to share relocation survey expenses equally. They also agreed to pay respondents P40,000.00 as costs of suit. Respondents later filed a motion to cite Renato and Teresita for contempt for non-compliance. The Petition: Petitioners, siblings of Renato and co-heirs to the lot, sought to intervene and substitute Renato and Teresita, alleging waiver of interest in their favor. They later filed a manifestation stating they would file a petition for relief from judgment, admitting that more than 60 days had passed since most of them learned of the compromise judgment, except for Luisito Villareal, who allegedly learned of it on June 20, 2000. The motion for intervention was denied. Luisito, through his attorney-in-fact Teresita Villareal Manipor, filed a petition for relief, which was denied by the RTC for lack of an affidavit of merit and for being filed beyond the six-month period from entry of judgment. Petitioners then filed a petition for annulment of the compromise judgment before the Court of Appeals (CA), which was dismissed for failure to explain the resort to registered mail. Their motion for reconsideration was also denied. They filed a second petition for annulment, which was dismissed for failure to show they could not have availed of ordinary remedies. The present appeal assails the CA's dismissal of the second petition for annulment.
Issue(s)
Whether the Court of Appeals erred in attributing fault to the petitioners for the denial of their petition for relief, thereby violating their right to due process. Whether the Court of Appeals erred in considering their original petition for annulment as not having been filed based on Section 11, Rule 13 of the Rules of Court. Whether the Court of Appeals erred in denying their motion for reconsideration for failure to state material dates as provided under Section 1, Rule 9 of the Revised Internal Rules of the Court of Appeals. Whether the compromise judgment is null and void for failure to implead petitioners as indispensable parties-defendants.
Ruling
The petition is denied, and the dismissal of the petition for annulment in CA-G.R. SP No. 66192 is affirmed.
Ratio Decidendi
On the Court of Appeals' attribution of fault and violation of due process: The Court held that petitioners are precluded from resurrecting issues relative to the resolutions denying their first petition for annulment and motion for reconsideration, as these had lapsed into finality due to their failure to appeal. Basic is the rule that perfection of an appeal within the prescribed period is mandatory and jurisdictional; failure to do so renders the judgment final and executory. Therefore, petitioners cannot raise these issues again. On the Court of Appeals' consideration of the original petition for annulment: The Court affirmed the CA's dismissal of the first petition for annulment for failure to explain the resort to registered mail as required by Section 11, Rule 13 of the Rules of Court. This rule applies to all pleadings and motions filed with the court. The subsequent denial of the motion for reconsideration for failure to state material dates further solidified the finality of that resolution. On the Court of Appeals' denial of the motion for reconsideration: The Court reiterated that the denial of the motion for reconsideration for failure to state material dates, in violation of Section 1, Rule 9 of the Revised Internal Rules of the Court of Appeals, was a valid ground for dismissal. This procedural defect prevented the appellate court from properly assessing the timeliness and merits of the motion. On the nullity of the compromise judgment for non-joinder of indispensable parties: The Court ruled that the compromise judgment was not null and void for failure to implead the petitioners. The certificate of title showed Renato Villareal as the sole registered owner, and respondents could not be expected to know of any alleged interests of the petitioners not reflected on the title. Furthermore, petitioners admitted in a sworn statement that they donated and caused the registration of the lot in Renato's name, which constituted a waiver of their interest and estopped them from later claiming co-ownership. Thus, Renato was the only indispensable party-defendant, and his participation was sufficient for the RTC to exercise its jurisdiction.
Main Doctrine
A petition for annulment of judgment under Rule 47 is not a substitute for the ordinary remedies of new trial, appeal, or petition for relief from judgment. If a party fails to avail of these remedies without sufficient justification, they cannot subsequently file an action for annulment. Furthermore, a compromise judgment is immediately executory upon its approval, and the six-month period for filing a petition for relief under Rule 38 commences from its rendition.