National Mines and Allied Workers Union v. Calderon-Bargas
REITERATIONFacts
The Antecedents: Petitioner National Mines and Allied Workers Union (NAMAWU) filed a complaint with the National Labor Relations Commission (NLRC) for unfair labor practice, illegal dismissal, and monetary claims against private respondent Norma G. Mitra. The NLRC rendered a decision in favor of the workers, ordering private respondent to pay ₱1,669,897. A writ of execution was issued, and a parcel of land belonging to private respondent was levied upon and subsequently acquired by petitioner as the highest bidder. Procedural History: Private respondent filed a civil complaint for the annulment of the deed of sale, certificate of sale, notice of levy, and cancellation of title against petitioner, the sheriff, and the Register of Deeds. The Regional Trial Court (RTC), Branch 78, Morong, Rizal, initially dismissed the complaint for lack of jurisdiction, ruling that it was an offshoot of a labor dispute. The RTC denied private respondent's motion for reconsideration, noting that the complaint questioned not only the sheriff's procedure but also the labor arbiter's procedure due to alleged lack of notice. The RTC's orders became final and executory as private respondent failed to appeal. The Petition: Subsequently, private respondent filed a Motion to Admit Amended Complaint, citing the RTC's June 19, 2002 Order which suggested the need to amend the complaint. Petitioner opposed this motion, arguing it was filed out of time, substantially changed the cause of action, sought to alter a final judgment, intended to confer jurisdiction, and was meant to delay proceedings. The RTC granted the motion to admit the amended complaint. Petitioner then filed a petition for certiorari and prohibition, seeking to annul the RTC's January 30, 2003 Order.
Issue(s)
Whether the public respondent acted without jurisdiction and with grave abuse of discretion in issuing the Order dated January 30, 2003, allowing private respondent's amended complaint, considering the finality of the dismissal of the original complaint. Whether the RTC retained jurisdiction to allow an amended complaint after its previous orders dismissing the original complaint had become final and executory.
Ruling
The petition is GRANTED. The Order dated January 30, 2003, of Presiding Judge Adelina Calderon-Bargas of the Regional Trial Court, Branch 78, Morong, Rizal, is SET ASIDE, and the Orders issued on January 21, 2002, and June 19, 2002, respectively dismissing private respondent's complaint and denying her motion for reconsideration are REINSTATED.
Ratio Decidendi
On the issue of jurisdiction and the allowance of an amended complaint after finality of judgment: The Supreme Court held that the public respondent acted without jurisdiction in issuing the assailed Order. Under the Rules of Court, a party may amend a pleading once as a matter of right before a responsive pleading is served. Thereafter, substantial amendments require leave of court, which may be refused if intended to delay. However, in this case, the motion to amend was filed after the RTC's order dismissing the complaint had become final and executory due to the private respondent's failure to perfect an appeal within the mandatory 15-day reglementary period. Once a decision or order becomes final and executory, the court that rendered it loses jurisdiction over the case, except for the execution thereof. Therefore, it was beyond the power of the RTC to amend or revoke its final and executory orders. The Court emphasized that the rule on perfection of appeals is mandatory, and failure to comply results in the decision becoming final and irreversible. The subsequent filing of an amended complaint, which essentially sought to relitigate issues already passed upon and to circumvent the finality of previous rulings, was an improper attempt to revive a dismissed case and confer jurisdiction where none existed. The private respondent's claim of not receiving notices, while potentially a ground for relief if raised timely, could not override the established procedural rules on finality of judgments when invoked after the reglementary period for appeal had lapsed. On the issue of the RTC retaining jurisdiction: The Supreme Court held that the RTC did not retain jurisdiction to allow an amended complaint after its previous orders dismissing the original complaint had become final and executory. Once a decision or order becomes final and executory, the court that rendered it loses jurisdiction over the case, except for the execution thereof. Therefore, it was beyond the power of the RTC to amend or revoke its final and executory orders.
Main Doctrine
A court loses jurisdiction over a case, except to execute the same, after its orders have become final and executory due to the failure of the aggrieved party to perfect an appeal within the reglementary period. Consequently, a motion to amend a complaint filed after such finality, which seeks to alter the judgment or confer jurisdiction where none existed, must be denied.