Barco v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns a dispute over the paternity and surname of a child, June Salvacion, born on June 9, 1978, to Nadina Maravilla. Nadina was married to Francisco Maravilla on December 24, 1970, but they separated in February 1977 and later obtained an ecclesiastical annulment. June's birth certificate listed Francisco as the father and Maravilla as her surname. Nadina later claimed that Armando Gustilo, a married Congressman, was June's biological father. Nadina and Gustilo married in the United States on August 21, 1982, and Nadina obtained a judicial annulment of her marriage to Francisco on March 12, 1985. Procedural History: On March 17, 1983, Nadina filed a petition with the Regional Trial Court (RTC) of Makati to correct June's birth certificate, changing her surname to Gustilo and listing Armando Gustilo as the father. Francisco Maravilla consented to this petition. Armando Gustilo also filed a 'Constancia' acknowledging June as his daughter. The RTC, after publication and notice, granted the petition on January 7, 1985. Years later, Jose Vicente Gustilo, claiming to be Armando Gustilo's son, filed a petition with the Court of Appeals (CA) to annul the RTC order. Milagros Barco, as guardian for her daughter Mary Joy Ann Gustilo (also claiming to be Armando Gustilo's child), intervened in the CA proceedings. The CA dismissed both Jose Vicente's petition and Barco's complaint-in-intervention, finding no extrinsic fraud or lack of jurisdiction. Barco's motion for reconsideration was denied, leading to the present petition. The Petition: Milagros Barco, as guardian ad litem for Mary Joy Ann Gustilo, filed a Petition for Review on Certiorari with the Supreme Court, seeking to annul the RTC's January 7, 1985 order. Barco argues that the RTC lacked jurisdiction because she was not impleaded as a party, that the RTC erred in allowing substantial corrections to the birth certificate under Rule 108, that the petition was filed out of time, and that the RTC order contravened legal presumptions of legitimacy and surname rules. The Supreme Court, however, found that the RTC acquired jurisdiction through publication, that substantial corrections are permissible under Rule 108, and that any errors in the RTC's judgment were errors in the exercise of jurisdiction, not a lack thereof, and thus did not render the order void or subject to annulment.
Issue(s)
Whether the RTC Order granting the correction of entries in June's birth certificate is void for lack of jurisdiction over the parties. Whether the RTC had jurisdiction over the subject matter of Nadina's petition for correction of entries, considering the substantial nature of the corrections sought. Whether the petition for correction of entries had prescribed under the Civil Code. Whether Nadina's petition should have been treated as a petition for change of name. Whether the RTC Order contravened legal presumptions regarding legitimacy and surname. Whether Gustilo's Constancia was admissible as evidence.
Ruling
The Supreme Court dismissed the petition for lack of merit, affirming the Court of Appeals' decision. The RTC Order, despite apparent flaws, was not null and void and therefore could not be annulled. The Court held that jurisdiction was properly acquired through publication, and while errors may have been committed, they did not amount to a lack of jurisdiction that would warrant annulment.
Ratio Decidendi
On Jurisdiction over the Parties: The Court held that the RTC acquired jurisdiction over all indispensable parties, including Barco, through the notice by publication as required by Section 4 of Rule 108. The publication of the order setting the case for hearing serves to bind the whole world to the subsequent judgment, even parties who should have been impleaded but were inadvertently left out. This is because a petition for correction is an in rem proceeding, validated by publication, which brings the whole world as a party and vests the court with jurisdiction. On Jurisdiction over the Subject Matter: The Court reiterated that jurisdiction over the subject matter is conferred by law. It clarified that Rule 108, in conjunction with Article 412 of the Civil Code, allows for the correction of substantial errors in civil registry entries, not just innocuous or clerical ones, citing Republic v. Valencia and Lee v. Court of Appeals. The Court emphasized that the Judiciary Reorganization Act of 1980 conferred on the RTC exclusive original jurisdiction over civil actions where the subject matter is incapable of pecuniary estimation, which includes petitions for correction of entries. On Prescription and Capacity to Sue: The Court ruled that even if the petition for correction had prescribed or if Nadina lacked the capacity to file the action for change of name, these grounds would only render the judgment erroneous, not void. Prescription and lack of capacity to sue are grounds for dismissal, but their existence does not oust the court of its power to decide the case. Jurisdiction is conferred by law and cannot be waived or diminished by the parties' acts or omissions. Therefore, an erroneous judgment is not subject to annulment. On Legal Presumptions and Surname: The Court acknowledged that the RTC Order might have erred in directing the change of June's surname to Gustilo, as an illegitimate child should bear the mother's surname. It also noted that the RTC might have erred in adjudging Gustilo as the father based on Nadina's testimony, which has no probative value against the presumption of legitimacy, and in admitting Gustilo's Constancia. However, these were characterized as errors in the exercise of jurisdiction, not a lack of jurisdiction. Since the RTC Order had become final, the Court was precluded from reviewing these alleged errors in evidence appreciation. On Legal Presumptions and Surname (Continued): The Court acknowledged that the RTC Order might have erred in directing the change of June's surname to Gustilo, as an illegitimate child should bear the mother's surname. It also noted that the RTC might have erred in adjudging Gustilo as the father based on Nadina's testimony, which has no probative value against the presumption of legitimacy, and in admitting Gustilo's Constancia. However, these were characterized as errors in the exercise of jurisdiction, not a lack of jurisdiction. Since the RTC Order had become final, the Court was precluded from reviewing these alleged errors in evidence appreciation. On the Nature of Annulment of Judgment: The Court reiterated that annulment of judgment is an equitable remedy allowed only in exceptional cases, specifically on the grounds of extrinsic fraud or lack of jurisdiction, as provided in Rule 47 of the Rules of Civil Procedure. The purpose is to discharge a party from a judgment that is an absolute nullity. Since the RTC Order was found to have been rendered with jurisdiction, despite potential errors, it was not null and void and thus not subject to annulment.
Main Doctrine
A petition for annulment of judgment based on lack of jurisdiction requires an absolute absence of jurisdiction, not merely an abuse of discretion. While errors in judgment may exist, they do not render a judgment void if the court had jurisdiction over the parties and the subject matter. Publication of notice in Rule 108 proceedings confers jurisdiction over the parties and binds the whole world, even those not impleaded.