Mercado v. Mercado
REITERATIONFacts
The Antecedents: Petitioner Julio Mercado was issued a Certificate of Land Transfer (CLT) in 1976 and an Emancipation Patent (EP) in 1982 for an agricultural land owned by the grandfather of respondent Edmundo Mercado. Respondent, relying on a Certificate of Retention (CR) issued in his name, filed a complaint for rescission of contract, cancellation of CLT and EP, payment of rentals, and ejectment against petitioner. Respondent alleged irregular issuance of petitioner's CLT and EP, and non-payment of rentals since 1979. Procedural History: The Provincial Adjudication Board (PARAB) dismissed respondent's complaint, upholding the validity of petitioner's EP. On appeal, the DARAB reversed the PARAB decision, finding petitioner guilty of deliberate non-payment of lease rentals and ordering rescission of the contract, ejectment, and cancellation of the CLT and EP. The DARAB decision became final and executory. Petitioner's subsequent Petition for Certiorari before the Court of Appeals was dismissed due to the finality of the DARAB decision. A Petition for Review on Certiorari before the Supreme Court was also denied due to procedural flaws. Petitioner then filed a Petition for Relief from Judgment before the DARAB, which was denied. The Court of Appeals also denied petitioner's subsequent petition challenging the denial of his Petition for Relief and the original DARAB decision, citing the finality of the DARAB ruling and petitioner's negligence. The Petition: Petitioner filed a Petition for Review on Certiorari before the Supreme Court, faulting the Court of Appeals for not according with law or applicable decisions, and reiterating arguments that the DARAB decision was rendered without or in excess of jurisdiction, that respondent's claim was barred by the statute of limitations, and that his constitutional right to due process was violated.
Issue(s)
Whether the DARAB decision in DARAB Case No. 4389, having become final and executory, could still be modified or set aside. Whether the DARAB had jurisdiction over the case, considering the issuance of an Emancipation Patent to the petitioner. Whether the petitioner was deprived of due process. Whether the Court of Appeals erred in affirming the denial of the Petition for Relief from Judgment.
Ruling
The petition is denied. The Decision of the Court of Appeals dated March 21, 2007, is affirmed. Double costs against the petitioner.
Ratio Decidendi
On the finality and executory nature of the DARAB decision: The Supreme Court reiterated the principle that a decision that has become final and executory is immutable and unalterable. It can no longer be modified in any respect, even to correct erroneous conclusions of fact or law. The exceptions to this rule, namely the correction of clerical errors, nunc pro tunc entries that cause no prejudice, and void judgments, were found to be absent in this case. Therefore, the DARAB decision in DARAB Case No. 4389, having attained finality, could not be subject to further modification or review on its merits. On the jurisdiction of the DARAB: The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint. Respondent's complaint alleged the existence of a tenancy relationship, which is a valid basis for DARAB's jurisdiction. Furthermore, the Court clarified that the mere issuance of an emancipation patent does not place the ownership of the agrarian reform beneficiary beyond attack or scrutiny, as emancipation patents may be cancelled for violations of agrarian laws. The Court cited Ayo-Alburo v. Matobato to support the proposition that DARAB has jurisdiction over cases involving the cancellation of emancipation patents. The Court also noted that petitioner actively participated in the proceedings below, estopping him from questioning the DARAB's jurisdiction at such a late stage. On the alleged deprivation of due process: The Court found that the petitioner's claim of being deprived of due process was unsubstantiated by the records. The records indicated that petitioner's former counsel withdrew, and while a new counsel was secured, the petitioner failed to file an answer or comment to the appeal memorandum within the given period. The Court noted that even petitioner's subsequent counsel conceded that no new matters were presented to justify a reversal of the decision. The Court concluded that petitioner was negligent in protecting his rights and that the Court of Appeals' finding of negligence was well-taken. The Court emphasized that while liberality in due process is recognized, it should be extended to those vigilant in protecting their rights. On the denial of the Petition for Relief from Judgment: The Court affirmed the denial of the Petition for Relief from Judgment, citing Rule XVI of the 2003 DARAB Rules of Procedure. The rule requires that such a petition must be filed within sixty days from discovery of fraud, mistake, or excusable negligence and within six months after the decision was rendered. Moreover, relief is available only against the decision of an adjudicator and when the party seeking it has no other adequate remedy. In this case, petitioner sought relief from the DARAB decision, not that of an adjudicator, before the DARAB itself, thus failing to meet the procedural requirements.
Main Doctrine
The finality and executory nature of a DARAB decision renders it immutable and unalterable, barring modification except for clerical errors, nunc pro tunc entries without prejudice, or void judgments. Active participation in proceedings estops a party from questioning jurisdiction at a later stage. Relief from judgment is strictly governed by procedural rules regarding timing and the nature of the decision from which relief is sought.