Republic of the Philippines (Department of Environment and Natural Resources) v. Technological Advocates for Agro-Forest Programs Association, Inc.
REITERATIONFacts
The Antecedents: Respondent Technological Advocates for Agro-Forest Programs Association, Inc. (TAFPA) entered into a contract with the Department of Environment and Natural Resources (DENR) for community organizing and related activities. After completing the contracted services, TAFPA submitted accomplishment reports and requests for payment. The Composite Inspection Committee validated these reports and recommended payment of P802,350.64. However, the DENR, through its Regional Executive Director, sought to impose a penalty for alleged delay in report submission, claiming TAFPA owed the DENR P390,260.36. TAFPA contested this, and a legal opinion clarified that the penalty clause applied to delays in service completion, not report submission. Despite this, the DENR maintained its position, suggesting TAFPA seek equitable reduction of the penalty in court. Procedural History: TAFPA filed a special civil action for Mandamus with Prayer for Damages against the DENR before the Regional Trial Court (RTC), seeking payment of its claims. The RTC treated the case as one for specific performance. After TAFPA filed a motion for judgment on the pleadings, which the DENR did not oppose, the RTC granted the motion. Subsequently, the RTC rendered a decision in favor of TAFPA, ordering the DENR to pay the unpaid claim and attorney's fees. The DENR's motion for reconsideration was denied, and the judgment became final and executory. The RTC then issued a writ of execution. The Office of the Solicitor General (OSG) filed a motion to set aside the decision, citing lack of due process, which the RTC denied. The DENR filed a Notice of Appeal, but the RTC disapproved it, emphasizing that the decision had become final and executory. Aggrieved, the DENR filed a petition for Annulment of Judgment with the Court of Appeals (CA), which was also denied. The CA affirmed the RTC's decision, finding that the RTC had jurisdiction and that the DENR's right to due process was not violated. The Petition: The Republic of the Philippines, through the DENR, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. The petitioner argues that the CA erred in upholding the finality of the trial court's judgment, contending that notice to a deputized counsel is not binding on the OSG, thus violating its right to due process. Petitioner also claims the CA erred in affirming the denial of its right to due process and in ruling against the petitioner, which it asserts was not a party to the original mandamus case. The core of the petition revolves around the alleged lack of proper notice to the OSG, which petitioner claims prevented the judgment from becoming final and executory and constituted a violation of due process.
Issue(s)
Whether the Court of Appeals erred in upholding the finality of the trial court’s judgment on the ground that notice to the deputized counsel is notice to the OSG. Whether the Court of Appeals erred in affirming the denial of petitioner’s right to due process by upholding the trial court’s order for the release of funds in favor of respondent. Whether the Court of Appeals erred in ruling against petitioner which was not even a party to the case for mandamus filed by respondent before the trial court.
Ruling
The petition is DENIED. The Decision dated September 9, 2004 of the Court of Appeals (CA) in CA-G.R. SP No. 76176 is AFFIRMED.
Ratio Decidendi
On the issue of notice to deputized counsel and due process: The Court held that notice to a deputized counsel is binding on the principal counsel, the Office of the Solicitor General (OSG). Atty. Vidzfar A. Julie was duly deputized by the OSG to assist in the case, and he entered his appearance as counsel for DENR. As the counsel on record, notices of court processes sent to him were sufficient to bind the petitioner. The records also showed that the OSG was officially notified of the case through various communications and forwarded documents, indicating awareness of the proceedings. Therefore, the petitioner's right to due process was not violated, as it was given ample opportunity to participate in the proceedings. The failure of the deputized counsel or the OSG to appeal the decision or avail of other remedies within the prescribed period rendered the decision final and executory, barring an action for annulment of judgment. On the issue of the RTC’s jurisdiction and denial of due process: The Court affirmed the CA's conclusion that the RTC acquired jurisdiction over the respondent's cause of action. The action was initially filed as mandamus but was correctly treated by the RTC as a case for specific performance, which falls within the original jurisdiction of the Regional Trial Courts under Batas Pambansa Bilang 129. The RTC also has exclusive original jurisdiction over cases where the subject of litigation is incapable of pecuniary estimation and cases where the demand exceeds ₱100,000.00, which applied to the present case. Therefore, the RTC did not lack jurisdiction over the subject matter. On the issue of petitioner not being a party to the mandamus case: The Court found this argument to be without merit. The records clearly showed that DENR, through its legal officers and later its deputized counsel, participated in the proceedings before the RTC. It filed pleadings, participated in pre-trial, and was furnished copies of orders and decisions. Having participated in the proceedings and submitted the case for decision, DENR could not later attack the judgment on the ground that it was not a party. The Court reiterated that a party who participates in a case and accepts a favorable judgment cannot later assail it when it becomes adverse. The petition was an extraordinary remedy to annul a final judgment, and it could not be used to make a farce of a duly promulgated and executory decision.
Main Doctrine
Notice to a deputized counsel is binding on the principal counsel, and failure to appeal or avail of other remedies within the prescribed period renders the decision final and executory, barring an action for annulment of judgment based on alleged lack of due process.