Quelnan v. VHF Philippines, Inc.
REITERATIONFacts
The Antecedents: Respondent VHF Philippines, Inc. filed an ejectment suit against petitioner Andy Quelnan concerning a condominium unit. The Metropolitan Trial Court (MeTC) of Manila, finding that summons was served on petitioner's wife via substituted service and that petitioner failed to file an answer, rendered a default judgment in favor of the respondent. This judgment ordered petitioner to vacate the premises, pay substantial amounts for back rentals and future monthly rentals, and cover attorney's fees and costs. Procedural History: Following the MeTC's default judgment, which became final and executory due to petitioner's failure to appeal, a writ of execution was issued. Petitioner subsequently filed a Petition for Relief from Judgment with the Regional Trial Court (RTC), alleging he was unaware of the proceedings due to his wife's actions. The RTC granted this petition, setting aside the MeTC decision. However, the respondent appealed to the Court of Appeals (CA), which reversed the RTC's decision, reinstating the MeTC judgment. The CA found that the petition for relief was filed beyond the reglementary period. The Petition: Petitioner seeks review of the CA's decision and resolution, arguing that the MeTC never acquired jurisdiction over him and that his petition for relief was timely filed. He contends that the 60-day period for filing a petition for relief should commence from his actual knowledge of the judgment, which he claims was only on May 18, 1993. The core of his argument rests on the assertion that his wife's destruction of the summons constituted excusable negligence, preventing him from knowing about the case and filing a timely appeal or petition. He also raises issues regarding the CA's consideration of prior RTC orders and the evidentiary support for the MeTC's findings.
Issue(s)
Whether the Court of Appeals erred in reversing the Regional Trial Court's decision. Whether the Metropolitan Trial Court acquired jurisdiction over the petitioner. Whether the Metropolitan Trial Court's findings of fact are supported by evidence. When is a party deemed to have knowledge of a judgment sent by registered mail that was returned unclaimed. Whether the presumption of completeness of service by registered mail applies in relation to the 60-day period for filing a petition for relief from judgment.
Ruling
The petition is denied, and the challenged decision and resolution of the Court of Appeals are affirmed. The Metropolitan Trial Court decision is reinstated.
Ratio Decidendi
On the Court of Appeals' Ruling: The Court found no error in the CA's decision to reverse the RTC and reinstate the MeTC decision, as the petition for relief was filed out of time and without sufficient basis for excusable negligence. On Jurisdiction and Finality of Judgment: The Court found that the MeTC acquired jurisdiction over the petitioner through substituted service of summons, which was effected in accordance with Section 7 of Rule 14 of the Rules of Civil Procedure. The MeTC decision became final and executory on December 15, 1992, fifteen days after November 30, 1992, when the first notice was deemed served. The Court reiterated the doctrine of finality of judgments, stating that once a judgment becomes final and executory, the prevailing party should not be denied the fruits of his victory by some subterfuge. The petition for relief could not render the final judgment abortive or impossible of execution. On Excusable Negligence: The Court disagreed with the RTC's finding of excusable negligence. The failure to claim a registered mail matter, despite notice from the postmaster, is not considered excusable neglect that would warrant the reopening of a decided case. The petitioner failed to offer any explanation for his inability to claim the mail. The Court emphasized that equity aids the vigilant, not those who slumber on their rights, and relief will not be granted if the loss of the remedy was due to the party's own negligence or mistaken procedure. On the timeliness of the Petition for Relief: The Court held that the 60-day period for filing a petition for relief from judgment under Rule 38 of the Rules of Court is reckoned from the date the petitioner learns of the judgment, order, or proceeding to be set aside. In this case, a copy of the MeTC decision was sent to petitioner by registered mail on November 25, 1992. Despite three notices from the postmaster, petitioner failed to claim the mail. Under Rule 13, Section 10 of the Rules of Civil Procedure, service by registered mail is complete upon actual receipt or five days from the date the addressee received the first notice from the postmaster, whichever is earlier. Since petitioner was first notified on November 25, 1992, service was deemed complete on November 30, 1992. Therefore, the 60-day period for filing the petition for relief expired on January 29, 1993. Petitioner filed his petition on May 24, 1993, 175 days after he was deemed to have learned of the judgment, thus it was filed beyond the reglementary period. On the Presumption of Completeness of Service: The Court affirmed the application of the presumption of completeness of service by registered mail. The RTC's view that the 60-day period starts only after actual knowledge, thereby disregarding the presumption, was deemed subject to abuse and contrary to jurisprudence. The burden was on the petitioner to prove that the postmaster's notice never reached him, which he failed to discharge. The postmaster's certification of non-claim was considered the best evidence that the notice was sent and delivered.
Main Doctrine
The 60-day period for filing a petition for relief from judgment under Rule 38 of the Rules of Court is reckoned from the date service of the judgment is deemed complete, which for registered mail, is five (5) days from the postmaster's first notice if the addressee fails to claim the mail. Failure to claim registered mail despite notice is not an excusable neglect that warrants reopening a decided case.