Grande v. University of the Philippines
REITERATIONFacts
The Antecedents: Petitioners sought the annulment of a Court of Appeals (CA) Decision and Resolution that dismissed their appeal from a Regional Trial Court (RTC) decision. The RTC had dismissed their complaint for recovery of ownership and reconveyance of a property, finding that the property was covered by a Torrens title as early as 1914 and that the respondent, University of the Philippines (UP), had acquired ownership as an innocent purchaser for value in 1984, seventy years after the title's issuance. Petitioners filed their action only in 1984. Procedural History: The CA dismissed petitioners' appeal. Petitioners received the CA Decision on December 28, 1998, and the Resolution denying their motion for reconsideration on March 17, 2000. They failed to elevate the CA rulings to the Supreme Court, claiming their former counsel neglected to inform them of the Resolution's receipt. Consequently, the CA Decision became final and executory on April 12, 2000, with an entry of judgment issued. Petitioners filed their "Petition for Annulment of Judgment" with the Supreme Court on June 29, 2001, over a year after the CA rulings became final. The Petition: Petitioners sought the annulment of the CA Decision and Resolution, alleging their former counsel's negligence. Respondent UP argued that the procedure undertaken by petitioners had no sanction under the Rules of Court.
Issue(s)
Whether the Supreme Court has original jurisdiction to entertain a petition for annulment of judgment of the Court of Appeals. Whether the alleged negligence of petitioners' former counsel justifies the annulment of the Court of Appeals' final and executory decision. Whether the petition, even if treated as a petition for review on certiorari or a special civil action for certiorari, was filed within the reglementary period.
Ruling
The petition is DISMISSED. The Court of Appeals Decision and Resolution are affirmed.
Ratio Decidendi
On the Supreme Court's jurisdiction over petitions for annulment of judgment: The Court reiterated that the annulment of judgments is generally governed by Rule 47 of the Rules of Civil Procedure, which applies only to petitions for the nullification of judgments rendered by regional trial courts filed with the Court of Appeals. It does not pertain to the nullification of decisions of the Court of Appeals. The Supreme Court's original jurisdiction is limited to specific cases enumerated in the Constitution and laws, and petitions for annulment of judgment are not among them. While the Court may, in exceptional circumstances, take cognizance of a petition over which it ordinarily has no jurisdiction, this is not applicable here. On the alleged negligence of counsel: The Court affirmed the well-settled rule that a client is bound by the conduct, negligence, and mistake of their counsel. Relief is granted only in cases of gross or palpable negligence. In this case, the petitioners failed to show such carelessness or negligence on the part of their lawyer to justify a deviation from the rule that clients are bound by their counsel's acts. The Court emphasized that the subsequent filing of a motion for reconsideration cannot disturb the finality of a judgment and restore jurisdiction that has already been lost. On the timeliness of the petition and the finality of judgment: Even if the petition were treated as an appeal by certiorari under Rule 45, it was filed several months after the Court of Appeals decision had become final and executory. The reglementary period for filing such an appeal is fifteen (15) days from notice of the judgment or final order. Similarly, if treated as a special civil action for certiorari under Rule 65, it was filed way beyond the period for filing such an action. Certiorari can only lie if there is no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law, which is not the situation here given the finality of the CA decision. The Court stressed the fundamental principle of the finality of judgment, stating that once a decision becomes final and executory, it is removed from the power of the court that rendered it to amend or revoke it. Reopening a case that has become final and executory is disallowed, as it defeats the purpose of courts to settle justiciable controversies with finality and maintain peace and order. The Court noted that the original complaint was filed in 1984 and the judgment became final in 2001, necessitating an end to the litigation. The Court also pointed out that the challenge to the decisions of the CA and RTC ultimately involved questions of fact, which both lower courts had already resolved with common findings. The Supreme Court is generally not inclined to engage in a re-examination of factual issues, especially in a case that has been pending for a long time and where the procedural remedies have been exhausted or lapsed.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court applies only to judgments of Regional Trial Courts filed with the Court of Appeals, not to decisions of the Court of Appeals itself. The Supreme Court does not have original jurisdiction over petitions for annulment of judgment of lower courts, and such petitions, even if treated as a petition for certiorari, must be filed within the prescribed reglementary periods. Clients are bound by the negligence of their counsel, unless gross or palpable negligence is proven.