Peña v. Government Service Insurance System
REITERATIONFacts
The Antecedents: Petitioner Felisa Peña acquired three subdivision lots from Queen's Row Subdivision, Inc. with a right to repurchase. However, Queen's Row Subdivision, Inc. failed to repurchase the lots and deliver the titles, as the lots had allegedly been mortgaged to the Government Service Insurance System (GSIS) without the required written approval from the Housing and Land Use Regulatory Board (HLURB) under Presidential Decree No. 957. Petitioner subsequently filed a complaint seeking the cancellation of the mortgage and consolidation of ownership in her favor, arguing the mortgage was void due to lack of HLURB approval. Procedural History: The Housing and Land Use Arbiter ruled in favor of the petitioner, declaring the sale valid, the mortgage voidable as to the petitioner, and ordering the cancellation of the mortgage annotation. The GSIS filed a Notice of Appeal, which the HLURB Arbiter denied, citing procedural rules requiring a Petition for Review. The GSIS then filed a Motion to Declare Judgment Null and Void Ab Initio with the HLURB Board of Commissioners, arguing lack of jurisdiction and exemption from PD 957. This motion was denied, as was a subsequent motion for reconsideration. The GSIS appealed to the Office of the President, which set aside the HLURB's order and declared the mortgage valid and subsisting. Petitioner appealed this decision to the Court of Appeals, which affirmed the Office of the President's ruling. Petitioner then filed the present petition with the Supreme Court. The Petition: Petitioner seeks review under Rule 45 of the Rules of Civil Procedure, arguing that the HLURB Regional Office's decision had become final and executory due to the GSIS's failure to file the proper mode of appeal within the reglementary period. Petitioner contends that neither the HLURB Board of Commissioners nor the Office of the President had the jurisdiction to revive, review, or alter a final and executory judgment. The Supreme Court is asked to determine if the Office of the President could set aside a final and executory judgment and if the Court of Appeals erred in affirming such a decision, thereby reinstating the original HLURB decision.
Issue(s)
Whether the Office of the President can set aside and reverse a judgment of the HLURB Regional Office that has long become final and executory for failure of the respondent to interpose the proper mode of appeal within the reglementary period as provided for in the 1994 Rules of Procedure of HLURB. Whether the Court of Appeals committed a reversible error in affirming the Decision of the Office of the President that reversed a final and executory judgment of the HLURB.
Ruling
The petition is GRANTED. The Court of Appeals and the Office of the President acted without jurisdiction in reviewing and reversing the final and executory Decision of the HLURB Regional Office dated December 20, 1995. The said decision is hereby REINSTATED.
Ratio Decidendi
On the issue of whether the Office of the President can set aside and reverse a final and executory judgment: The Supreme Court reiterated that the right to appeal is a statutory right that must be exercised in the manner and within the period prescribed by law. Failure to comply with these rules, particularly regarding the perfection of an appeal, renders the judgment final and executory. In this case, GSIS filed a Notice of Appeal instead of the required Petition for Review under the HLURB Rules, which was correctly denied. Consequently, the HLURB Regional Office's Decision dated December 20, 1995, became final and executory as early as March 1996. The Court emphasized that final and executory judgments are immutable and can no longer be attacked, modified, or altered, even by the highest court of the land, as this would violate the principle of res judicata and undermine the stability of judicial pronouncements. The Court stressed that procedural rules, especially those concerning appeal periods, are indispensable for preventing needless delays and ensuring the orderly administration of justice. On the issue of whether the Court of Appeals committed a reversible error: The Supreme Court held that since the Office of the President acted without jurisdiction in reversing a final and executory judgment, the Court of Appeals committed a reversible error in affirming such a decision. The Court clarified that administrative decisions, upon becoming final and executory, acquire the force and binding effect of a final judgment. Therefore, the Office of the President, even with its supervisory authority over HLURB, could not revive, review, change, or alter a decision that had already attained finality. The Court underscored that the principle of res judicata applies to the quasi-judicial acts of administrative bodies, and public policy demands that controversies be settled and finality be given to judgments to ensure stability and prevent endless litigation. The Court also affirmed that the HLURB has exclusive jurisdiction over cases involving unsound real estate business practices, including disputes over mortgages on subdivision lots, as expanded by Presidential Decree No. 1344 and subsequent executive issuances.
Main Doctrine
A final and executory judgment can no longer be modified or reviewed by any court or quasi-judicial body, as the perfection of an appeal within the reglementary period and in the manner prescribed by law is a jurisdictional requisite. Failure to comply with these rules renders the judgment immutable and unalterable.