National Housing Authority v. Noble
REITERATIONFacts
The Antecedents: On May 25, 1981, the National Housing Authority (NHA) initiated an expropriation case against respondents-landowners for their properties in Lapasan, Cagayan de Oro City. This action was undertaken pursuant to Letter of Instructions No. 555 and 557, which mandated a nationwide Slum Improvement and Resettlement Program. The case, docketed as Civil Case No. 7847, involved the transfer of properties to the NHA's control via a writ of possession. Procedural History: The case underwent several transfers between Regional Trial Court (RTC) branches. Initially, commissioners appraised the properties at P470.00 per square meter in 1984, which the RTC approved. The NHA appealed this valuation to the Court of Appeals (CA), which remanded the case for further proceedings on just compensation. A new set of commissioners later pegged the just compensation at P705.00 per square meter. The RTC issued an Order on August 3, 1998, approving this higher valuation. The NHA filed a motion for reconsideration, claiming late receipt of the order, but the RTC denied it, finding the motion belatedly filed. The NHA appealed this denial to the CA. The Petition: The Court of Appeals, in a Resolution dated June 30, 2006, dismissed the NHA's appeal, affirming the RTC's finding that the August 3, 1998 Order had become final and executory. The CA relied on the registry return receipt showing the NHA received the order on November 10, 1998, making its motion for reconsideration filed on March 11, 1999, significantly beyond the reglementary period. The NHA's petition for review on certiorari to the Supreme Court challenges this CA Resolution, arguing that the CA erred in deeming the order final and executory, particularly disputing the validity of the service of the order to a former employee.
Issue(s)
Whether the Court of Appeals erred in finding that the Assailed Order had already become final and executory. Whether the National Housing Authority's motion for reconsideration was filed within the reglementary period.
Ruling
The petition is without merit. The Resolution dated June 30, 2006 of the Court of Appeals in CA-G.R. CV No. 73725 is hereby AFFIRMED.
Ratio Decidendi
On the issue of whether the Assailed Order had become final and executory: The Court affirmed the CA's finding that the Assailed Order had become final and executory. The principle of immutability of judgment dictates that a decision that has attained finality can no longer be modified. This principle serves to avoid undue delays in the administration of justice and to put an end to judicial controversies. The NHA's claim of receiving the Order on March 3, 1999, and filing a motion for reconsideration on March 11, 1999, was contradicted by the registry return receipt showing receipt on November 10, 1998. The motion for reconsideration was filed more than four months after notice, far exceeding the 15-day reglementary period. Therefore, the RTC's judgment had already lapsed into finality. On the issue of whether the National Housing Authority's motion for reconsideration was filed within the reglementary period: The Court found the NHA's contention that Atty. Epifanio P. Recafia, who allegedly received the Order on November 10, 1998, had ceased to be connected with NHA in January 1997, to be untenable. The NHA failed to present sufficient proof to invalidate the service of the order on November 10, 1998, other than its bare assertions and a self-serving certification. The NHA also failed to present Atty. Recafia or his statement to disown his authority to receive the order on their behalf. The unsubstantiated assertions of the NHA could not prevail over the registry return receipt, which is accorded the presumption of regularity in the performance of official duty by postal officials. Consequently, the motion for reconsideration was indeed filed beyond the reglementary period, rendering the Assailed Order final and executory and not subject to further appellate review.
Main Doctrine
A judgment that has attained finality becomes immutable and unalterable, and cannot be modified, even to correct errors of fact or law. The failure to file a motion for reconsideration or appeal within the reglementary period renders the judgment final and executory, barring further appellate review.