Teh v. Tan
REITERATIONFacts
The Antecedents: Spouses Teh Lin and Lim Ay Go owned a parcel of land in Quezon City. Their daughter, Victoria L. Teh, was allegedly gifted this land through two Deeds of Donation executed by her parents in 1971. Later, other children of the spouses, namely Natividad Teh Tan, Teh Ki Tiat, and Jacinta Sia (representing Teh Ki Huat), filed a complaint alleging that Victoria fraudulently procured a Deed of Donation dated March 20, 1971, in her sole favor, to the exclusion of other donees, and that the signatures of their parents were forged. They sought the annulment of the Transfer Certificate of Title (TCT) No. 117548 issued in Victoria's name and the issuance of a new title in their names as co-owners. Procedural History: The Regional Trial Court (RTC) initially considered the complaint filed by Natividad, Teh Ki Tiat, and Jacinta Sia. Several parties, including other children of the spouses and successors-in-interest of Teh Ki Huat, filed motions to intervene. The RTC disregarded most of these interventions, leaving Teh Ki Tiat as the sole plaintiff. The RTC ultimately declared the March 20, 1971 Deed of Donation null and void, cancelled TCT No. 117548, upheld the validity of the January 29, 1971 and November 19, 1971 Deeds of Donation, and ordered the reinstatement of TCT No. 37337 in the names of Teh Lin and Lim Ay Go. Victoria Teh did not appeal this decision, which became final and executory. Subsequently, Victoria filed a Manifestation with the RTC, seeking to be declared the sole beneficiary of the November 19, 1971 Deed of Donation. The RTC denied this Manifestation, stating it was an attempt to appeal a final decision. Victoria then filed a Petition for Review with the Court of Appeals (CA), which dismissed her petition, holding that the RTC's decision had become final and executory and could not be altered. Victoria's motion for reconsideration was also denied. The Petition: This case is before the Supreme Court on a Petition for Review on Certiorari under Rule 45 of the Rules of Court. Petitioner Victoria L. Teh assails the Resolutions of the Court of Appeals dated January 10, 2008, and March 6, 2008. Petitioner argues that the CA gravely erred in outrightly dismissing her petition for certiorari, amounting to an abuse of discretion. She contends that the CA erred in ruling that her attempt to be declared the sole beneficiary of the November 19, 1971 Deed of Donation, despite the finality of the RTC's judgment, was an attempt to derive benefits from a void judgment. Petitioner also challenges the CA's finding that Teh Ki Tiat, as the remaining plaintiff, could prosecute the case. Essentially, petitioner seeks to have the final and executory decision of the RTC modified or clarified to declare her as the sole beneficiary of the November 19, 1971 Deed of Donation.
Issue(s)
Whether the Court of Appeals gravely erred in dismissing outright the petition for certiorari filed by petitioner. Whether the Court of Appeals committed a grave and serious error in ruling that petitioner sought to derive benefits from a void judgment while simultaneously praying to be adjudged the sole beneficiary of the Deed of Donation dated November 19, 1971. Whether the Court of Appeals grievously erred in ruling that Teh Ki Tiat could prosecute the case as the remaining plaintiff who stood to be benefited by the Deed of Donation dated January 29, 1971.
Ruling
The Petition is DENIED. The Resolutions dated January 10, 2008, and March 6, 2008, of the Court of Appeals in CA-G.R. SP No. 101550 are AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the issue of the Court of Appeals' dismissal of the petition for certiorari: The Supreme Court affirmed the CA's dismissal, holding that the RTC's decision had become final and executory. A judgment that has acquired finality is immutable and unalterable, and may no longer be modified in any respect, except for specific exceptions not present in this case. The Court emphasized that a special civil action for certiorari is a limited form of review and cannot be used as a substitute for a lapsed or lost appeal, especially when the failure to appeal was due to the party's own negligence or error in the choice of remedy. Petitioner's Manifestation was deemed a prohibited motion for reconsideration, as it sought to re-examine and re-evaluate evidence already considered by the RTC in its final judgment. The Court reiterated that once a judgment becomes final, all issues are resolved, and no action can be taken on it except to order its execution. On the issue of deriving benefits from a void judgment: The Court found no merit in petitioner's argument that she sought to derive benefits from a void judgment. The CA's resolution correctly pointed out the apparent contradiction in petitioner's stance: she questioned the validity of the RTC's judgment due to the non-substitution of a deceased plaintiff, yet simultaneously sought to benefit from that same judgment by asking to be declared the sole beneficiary of a deed of donation. The Supreme Court clarified that the RTC's decision, having become final and executory, was not void. The issue of substitution was a procedural matter that, if not raised and resolved within the reglementary period, did not automatically render the entire judgment void, especially when other parties continued to prosecute the case. The CA correctly noted that Teh Ki Tiat, as a remaining plaintiff who stood to be benefited, could continue prosecuting the case. On the issue of Teh Ki Tiat's capacity to prosecute the case: The Court agreed with the CA that Teh Ki Tiat, as one of the original plaintiffs and a party who stood to be benefited by the Deed of Donation dated January 29, 1971, could continue prosecuting the case even after the death of another plaintiff, Natividad Teh Tan. The RTC's decision explicitly declared the January 29, 1971 Deed of Donation as valid, which directly benefited Teh Ki Tiat. The failure to substitute the heirs of Natividad Teh Tan did not automatically nullify the entire proceedings or the final judgment, especially since the case proceeded to judgment with at least one other plaintiff actively participating. The RTC's decision, which was upheld by the CA, implicitly recognized Teh Ki Tiat's standing to continue the case.
Main Doctrine
A final and executory judgment is immutable and unalterable, and may no longer be modified in any respect, except for correction of clerical errors, nunc pro tunc entries, void judgments, or circumstances rendering execution unjust and inequitable. A motion seeking to re-examine evidence or alter the dispositive portion of a final judgment, even if framed as a clarification, is considered a prohibited motion for reconsideration.