Joven v. Calilung
REITERATIONFacts
The Antecedents: This case originated from an unlawful detainer action filed by Federico S. Calilung against Emiliano D. Joven. Calilung sought possession of leased premises and payment of substantial monthly compensation, attorney's fees, and costs. The Municipal Trial Court in Cities (MTCC) ruled in favor of Calilung, ordering Joven to vacate the premises and pay monthly rent of P110,000.00 with interest, plus attorney's fees. Procedural History: Aggrieved by the MTCC decision, Joven appealed to the Regional Trial Court (RTC). Subsequently, Calilung filed a sworn statement with the National Bureau of Investigation (NBI) alleging that Judge Wilfred Suriaga, who issued the MTCC decision, had demanded and received P300,000.00 from him for a favorable ruling. An entrapment operation led to Judge Suriaga's arrest. Joven then filed a complaint for annulment of judgment before the RTC, citing extrinsic fraud. This complaint was dismissed by the RTC, which reasoned that the MTCC decision had been superseded by an RTC decision and that the matter was now within the Court of Appeals' jurisdiction. Joven's motion for reconsideration was denied. Meanwhile, the Court of Appeals reversed an RTC order that had disqualified Joven's counsel and expunged his pleadings, ordering the suspension of the RTC decision pending resolution of the annulment case. The Petition: These consolidated cases involve two Petitions for Review on Certiorari under Rule 45 of the Rules of Civil Procedure. G.R. No. 140984 seeks to nullify the RTC's dismissal of Joven's complaint for annulment of judgment and the denial of his motion for reconsideration. G.R. No. 148970 seeks to annul the Court of Appeals' decision which reversed an RTC order and directed the suspension of proceedings in the appeal of the ejectment case. Both petitions ultimately question the validity of the MTCC decision procured through alleged extrinsic fraud, particularly in light of Judge Suriaga's subsequent dismissal from the judiciary for bribery.
Issue(s)
Whether the RTC erred in dismissing Joven's complaint for annulment of judgment based on the mootness of the MTCC decision, considering allegations of extrinsic fraud. Whether the judgment rendered by the MTCC in the unlawful detainer case should be annulled on the ground of extrinsic fraud due to the bribery of Judge Suriaga. Whether the Court of Appeals erred in reversing the RTC's order disqualifying Atty. Carmelino Roque and denying Joven's motion to suspend proceedings, given the subsequent declaration of the MTCC judgment as void.
Ruling
The Supreme Court granted the petition in G.R. No. 140984, reversed and set aside the RTC's dismissal of the complaint for annulment of judgment, and declared the MTCC decision null and void, ordering a new trial. The petition in G.R. No. 148970 was denied for being moot.
Ratio Decidendi
On the dismissal of the complaint for annulment of judgment: The RTC erred in dismissing Joven's complaint for annulment of judgment. The RTC declared the case moot and academic, reasoning that the MTCC decision was superseded by the RTC decision, which was then under appeal to the Court of Appeals. However, the RTC overlooked the fact that the annulment case was predicated on extrinsic fraud, specifically the bribery of Judge Suriaga. The subsequent affirmation of the MTCC decision by the RTC did not cure the defect of the original judgment, which was tainted by corruption. The RTC should have proceeded to hear the annulment case on its merits, especially since the Supreme Court later found Judge Suriaga guilty of bribery. On the annulment of the MTCC judgment due to extrinsic fraud: The judgment rendered by Judge Suriaga in the ejectment case must be annulled because it was procured by the prevailing party through extrinsic fraud. The Supreme Court's finding in the administrative case that Judge Suriaga was guilty of bribery, demanding and receiving money from Calilung, irrevocably tainted the judgment with corruption. This bribery prevented Joven from having a fair trial and a real contest, as the outcome was predetermined. Extrinsic fraud operates on the manner in which a judgment was procured, preventing a fair submission of the controversy, which is precisely what occurred here. On the disqualification of counsel and suspension of proceedings: The Court of Appeals correctly reversed and set aside the RTC's order disqualifying Atty. Carmelino Roque and expunging his pleadings, and denying Joven's motion to suspend proceedings. The disqualification and expungement were based on the RTC's erroneous premise that the MTCC judgment was valid. Given that the MTCC judgment was later declared void due to extrinsic fraud, the basis for disqualifying Joven's counsel and denying the suspension of proceedings evaporated. The CA's order suspending the effectivity of the RTC's judgment pending the final termination of the annulment case was thus proper.
Main Doctrine
A judgment procured through extrinsic fraud, such as bribery by the prevailing party, is void and may be annulled. The integrity of the judiciary demands that judgments obtained through illegal and immoral means should not be given legal effect.