Dela Cruz v. Court of Appeals
REITERATIONFacts
The Antecedents: Antonio Mirabel, Jr. filed a complaint against Emiliana S. de la Cruz seeking the declaration of nullity of checks issued by Mirabel and for damages. Summons was duly served upon petitioner de la Cruz. Procedural History: Petitioner de la Cruz was declared in default by the Regional Trial Court (RTC) for failure to file an Answer within the extended period. The RTC subsequently rendered a judgment declaring two checks void and ordering petitioner to pay damages and attorney's fees. Petitioner's motion to lift the order of default and for reconsideration was denied. An appeal to the Court of Appeals (CA) was dismissed for failure to file an appellant's brief within the granted extension. A subsequent petition for review on certiorari before the Supreme Court (SC) was denied, with the SC holding that petitioner was bound by her counsel's negligence and that the RTC decision had become final. Notwithstanding, petitioner filed a Petition for Annulment of Judgment before the CA, which was also dismissed. The CA's dismissal was based on the principle of res judicata and the fact that the SC had already ruled on the finality of the RTC decision. The Petition: This petition for review on certiorari assails the CA's Resolution dismissing the Petition for Annulment of Judgment and its subsequent Resolution denying the Motion for Reconsideration. Petitioner argues that the CA gravely abused its discretion in dismissing the petition for annulment of judgment, asserting that the trial court lacked jurisdiction over the subject matter and gravely abused its discretion in rendering the judgment on the pleadings hastily. The SC, however, finds the petition without merit, reiterating that a petition for annulment of judgment is an equitable remedy available only in exceptional circumstances and that petitioner is bound by her counsel's negligence, which led to the finality of the RTC decision. The SC also notes that the issues raised regarding jurisdiction and the merits of the case should have been raised in the earlier appeal and that petitioner cannot attack a final decision through a petition for annulment of judgment.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in dismissing the petition for annulment of judgment. Whether the trial court lacked jurisdiction over the subject matter of the complaint. Whether the judgment on the pleadings was rendered hastily, amounting to a lack or excess of jurisdiction; and whether the principle of res judicata applies.
Ruling
The petition is denied. The Resolution dated January 16, 2002, of the Court of Appeals dismissing petitioner's Petition for Annulment of Judgment and the Resolution dated January 15, 2003, denying petitioner's Motion for Reconsideration are affirmed.
Ratio Decidendi
On the propriety of the Petition for Annulment of Judgment: The Supreme Court reiterated that a petition for annulment of judgment is an equitable remedy available only in exceptional cases where ordinary remedies like new trial, appeal, or petition for relief are no longer available through no fault of the petitioner. It can only be based on extrinsic fraud or lack of jurisdiction. In this case, the petitioner had available remedies, including appeal, which she pursued but failed to prosecute due to her counsel's negligence. The Court emphasized that the remedy of appeal was not lost through no fault of the petitioner, as she was bound by her counsel's negligence, a point already settled in a previous Supreme Court resolution. The Supreme Court reiterated its previous pronouncement that petitioner is bound by her counsel's negligence. This principle is well-established in jurisprudence, and the right to appeal is a mere privilege that must be exercised in the manner prescribed by law. The failure of counsel to file the required pleadings within the reglementary periods, even after extensions were granted, constitutes negligence that binds the client. On the alleged lack of jurisdiction of the trial court: The Court found no merit in the petitioner's claim that the trial court's decision was void for lack of jurisdiction. By previously declaring the trial court's decision final in G.R. No. 148073, the Supreme Court had, in effect, ruled that the trial court properly acquired jurisdiction over the subject matter and correctly disposed of the case. Therefore, the petitioner could no longer attack the final decision through a petition for annulment of judgment. On the alleged hasty rendition of judgment on the pleadings and the principle of res judicata: The Court held that issues regarding the alleged lack of jurisdiction, insufficiency of allegations, and hasty resolution of the complaint should have been raised in the petition for review before the Court of Appeals. However, the petitioner failed to file her appellant's brief despite several extensions. The Court noted that in her motion for reconsideration of the dismissal of her appeal, the petitioner claimed a meritorious defense but failed to attach her appellant's brief or an affidavit of merit, which the CA found persuasive. The Court of Appeals correctly pointed out that the instant petition attempts to relitigate issues already passed upon by the Supreme Court. The principle of res judicata, founded on public policy and necessity, dictates that there should be an end to litigation, and a party should not be vexed twice for the same cause of action. The issues raised in the petition for annulment of judgment were substantially the same issues that were, or could have been, raised in the previous petition for review before the Supreme Court.
Main Doctrine
A petition for annulment of judgment is an equitable remedy available only in exceptional cases where ordinary remedies are no longer available through no fault of the petitioner, and can only be based on extrinsic fraud or lack of jurisdiction. Furthermore, the principle of res judicata bars the relitigation of issues already passed upon and decided by a court of competent jurisdiction.