Reyes v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents Voluntad obtained a loan secured by a mortgage over a parcel of land. Upon failure to pay, the bank foreclosed the mortgage and sold the property at public auction. The bank assigned its right to the property to Spouses Dizon, who in turn sold it to petitioners Spouses Reyes while the property was under litigation. The Voluntads filed a Petition for Redemption (Civil Case No. 142-M-93) and caused a notice of lis pendens to be annotated. The RTC ruled in favor of the Voluntads, ordering the Dizon Spouses to render an accounting and allowing the Voluntads to redeem the property. Procedural History: The Voluntads filed a petition for Certiorari and Mandamus concerning the denial of a writ of execution against the transferees, herein petitioners Spouses Reyes. In G.R. No. 132294, the Supreme Court ruled in favor of the Voluntads, remanding the case for the immediate issuance of a Second Alias Writ of Execution against Spouses Reyes to enforce the RTC decision. Petitioners' motion for reconsideration was denied. The Petition: Contending they were not given their day in court and that their inability to intervene was due to excusable negligence, petitioners Reyes filed a Petition for Relief from Judgment on June 21, 2000. The RTC dismissed this petition on August 9, 2000, finding it filed out of time and that petitioners lacked legal personality. The RTC denied their motion for reconsideration on October 25, 2000. Petitioners elevated the matter to the Court of Appeals (CA) via certiorari, arguing grave abuse of discretion. The CA dismissed their petition, affirming the RTC orders. The CA ruled that the 60-day period commenced at the latest on May 30, 1997, when petitioners received an order directing them to comment on a petition for certiorari and mandamus, which had a copy of the RTC decision attached. The six-month period expired on June 8, 1996, from the entry of the RTC judgment on December 8, 1995.
Issue(s)
Whether the Petition for Relief from Judgment was filed within the reglementary periods prescribed by the Rules of Court. Whether the commencement of the 60-day period for filing a petition for relief from judgment should be reckoned from the time the petitioners, as transferees pendente lite, learned of the original judgment, even if they believed it was not binding upon them.
Ruling
The petition is denied. The Court of Appeals committed no reversible error in affirming the dismissal of the Petition for Relief from Judgment.
Ratio Decidendi
On the reglementary periods for filing a petition for relief from judgment: The Court reiterated that a petition for relief from judgment must be filed within sixty (60) days after the petitioner learns of the judgment, final order, or other proceeding to be set aside, and not more than six (6) months after such judgment or final order was entered. These two periods must concur. The Court emphasized that these periods are inextendible and uninterruptible, and strict compliance is mandatory due to the equitable character of the remedy. In the present case, the RTC judgment was entered on December 8, 1995. The six-month period expired on June 8, 1996. The petitioners learned of the RTC decision on May 30, 1997, when they received an order from the CA directing them to comment on a petition for certiorari and mandamus, to which a copy of the RTC decision was attached. The 60-day period from this knowledge would have expired on July 30, 1997. Since the petition for relief was filed on June 21, 2000, it was filed beyond both the 60-day period from knowledge and the six-month period from entry of judgment. Therefore, the petition was filed out of time. On the commencement of the 60-day period for transferees pendente lite: The Court rejected the petitioners' contention that the 60-day period should only commence from the time they learned with certainty that they were bound by the RTC decision, which they claimed was only after the Supreme Court's ruling in G.R. No. 132294. The Court held that the commencement of the 60-day period cannot be subjectively dependent upon any erroneous belief or mistaken ruling regarding the binding effect of a judgment, especially for transferees pendente lite who are deemed buyers in mala fide and stand in the shoes of the transferor. The Rules are clear that the period is reckoned from the time the petitioner learns of the judgment to be set aside. In this case, petitioners learned of the December 8, 1995 RTC decision on May 30, 1997, when they received the CA order with the decision attached. The Court stressed that the Rules and jurisprudence on transferees pendente lite have the force of law, and the objective application of rules, particularly jurisdictional matters like reglementary periods, must be upheld, following the principle of 'dura lex sed lex'.
Main Doctrine
A petition for relief from judgment must be filed within sixty (60) days from knowledge of the judgment, final order, or other proceeding to be set aside, and not more than six (6) months after such judgment or final order was entered. Both periods must concur and are inextendible and uninterruptible. The commencement of the 60-day period is reckoned from the time the petitioner learns of the judgment sought to be set aside, irrespective of any erroneous belief or mistaken ruling that the judgment is not binding upon them, especially when they are transferees pendente lite.