Heirs of So v. Obliosca
REITERATIONFacts
The Antecedents: Pantaleon Jomoc owned a parcel of land which, upon his death, was inherited by his heirs, including respondents Lucila Jomoc Obliosca, Abundia Jomoc Balala, and Elvira Jomoc. In February 1979, the Jomoc heirs executed a Deed of Extrajudicial Settlement with Absolute Sale in favor of petitioner Maura So for P300,000.00, though the respondents and Maura So did not sign it, and it was not notarized. Petitioner made a partial payment of P49,000.00. When the Jomoc heirs ignored demands for a final deed, petitioner filed a complaint for specific performance on February 24, 1983, impleading all Jomoc heirs except the respondents. Subsequently, on February 28, 1983, the Jomoc heirs executed another Deed of Extrajudicial Settlement with Absolute Sale of the same property in favor of the spouses Lim Liong Kang and Lim Pue King, who intervened in the specific performance case. Procedural History: The trial court ruled in favor of petitioner Maura So in the specific performance case, which was affirmed by the Court of Appeals (CA) with modifications. Separate petitions for review by the defendant heirs and the spouses Lim were consolidated, and this Court, in a Decision dated August 2, 1991 (G.R. Nos. 92871 and 92860), upheld petitioner's better right to the property, which became final and executory on November 25, 1991. Despite respondents not being parties to the original case, the trial court granted petitioner's motion for execution, divesting all Jomoc heirs of their titles. The CA dismissed the petition for certiorari filed by the Jomoc heirs, holding respondents bound by the decision due to their awareness and failure to intervene, a ruling affirmed by this Court in G.R. No. 110661. Meanwhile, respondents filed a complaint for legal redemption on March 12, 1992, which the RTC granted, ordering petitioner to allow redemption and execute necessary documents. Petitioner's subsequent petition for review of this RTC order was denied by this Court in G.R. No. 118050. The Petition: Petitioners, heirs of Maura So, filed a petition for review on certiorari seeking to reverse the CA's Decision and Resolution that denied their petition for annulment of judgment. The CA held that annulment was unavailable as petitioner had already filed a petition for review under Rule 45. Petitioners argue the RTC acted without jurisdiction in the legal redemption case by contradicting prior Supreme Court decisions and that the CA erred in barring their petition for annulment by res judicata. The Supreme Court, while acknowledging the procedural restrictions, granted the petition to prevent injustice, finding that the RTC's decision in the legal redemption case conflicted with earlier, final, and executory Supreme Court decisions that had already established the sale of the entire property to Maura So, and that the RTC was barred by the doctrine of conclusiveness of judgment. The Court prioritized the earlier Supreme Court decisions, setting aside the RTC's resolution and dismissing the complaint for legal redemption.
Issue(s)
Whether the Court of Appeals erred in holding that a petition for annulment of judgment cannot be availed of when a petition for review under Rule 45 has already been filed. Whether the Regional Trial Court acted without jurisdiction in Civil Case No. 92-135 by rendering a decision that allegedly contradicted prior Supreme Court decisions. Whether the Court of Appeals erred in holding that the petition for annulment of judgment was barred by res judicata and the effect of conflicting Supreme Court decisions.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals dated October 18, 2000, and Resolution dated January 11, 2001, are REVERSED. The April 27, 1994 Resolution and September 7, 1994 Order of the RTC are SET ASIDE. The complaint for legal redemption docketed as Civil Case No. 92-135 is DISMISSED.
Ratio Decidendi
On the availability of annulment of judgment: The Court acknowledged the general rule that a petition for annulment of judgment is an equitable remedy available only in exceptional cases where no other adequate remedy exists, and it cannot be invoked if the party has already availed of or failed to avail of other remedies like appeal. However, the Court emphasized that rules of procedure are tools to promote substantial justice and can be suspended or disregarded to prevent grave injustice. In this case, the Court chose to brush aside procedural norms due to the peculiar circumstances involving conflicting final and executory judgments. On the RTC acting without jurisdiction: The Court clarified that petitioners confused lack of jurisdiction with an error in the exercise of jurisdiction. Jurisdiction is the authority to decide a case, while errors in judgment are subject to appeal. The RTC had jurisdiction over the legal redemption case. The alleged error of contradicting prior Supreme Court decisions was an error in judgment, not a lack of jurisdiction, and thus not a valid ground for annulment of judgment based on lack of jurisdiction. On res judicata and conflicting decisions: The Court noted the existence of three conflicting final and executory judgments: (1) the Supreme Court's decision upholding the sale of the whole property to Maura So (G.R. Nos. 92871 and 92860); (2) the Supreme Court's resolution sustaining the execution of that decision against respondents (G.R. No. 110661); and (3) the Supreme Court's minute resolution denying Maura So's petition for review of the RTC decision granting respondents the right to redeem (G.R. No. 118050). The Court found the third judgment, which was a minute resolution, to be in conflict with the first two, which were decisions on the merits. Applying the principles of conclusiveness of judgment and prioritizing earlier decisions from higher courts, the Court held that the RTC's decision in the legal redemption case was erroneous as it was barred by the prior Supreme Court rulings. The Court found that the complaint for legal redemption was a ploy to circumvent previous decisions and that blind adherence to immutability of judgment would sacrifice justice for technicality.
Main Doctrine
While procedural rules ordinarily bar the annulment of judgment when other remedies have been availed of, and the principle of finality of judgment is sacrosanct, the Court may suspend these rules to prevent grave injustice, especially when faced with conflicting final and executory decisions, prioritizing earlier decisions from higher courts.