Mendoza v. Bangko Kabayan
REITERATIONFacts
The Antecedents: Petitioners Ligaya and Adelia Mendoza obtained a loan of ₱12,000,000.00 from Bangko Kabayan, secured by a real estate mortgage over 71 parcels of land. Petitioners defaulted on the loan. Procedural History: Bangko Kabayan filed a complaint for judicial foreclosure. The Regional Trial Court (RTC) rendered a Judgment on the Pleadings in favor of the bank, ordering petitioners to pay the loan amount with interest and penalties, or face public auction of the mortgaged properties. Petitioners failed to file an appeal or motion for reconsideration within the reglementary period. The bank filed a Motion for Execution. Petitioners opposed, claiming they were not duly served with a copy of the RTC Decision. The RTC denied their Notice of Appeal for being filed out of time, holding their counsel negligent. The RTC ordered the issuance of a writ of execution. Petitioners' Motion for Reconsideration was denied, and the Sheriff was ordered to proceed with the sale of the properties. The Petition: Petitioners filed a Petition for Certiorari with the Court of Appeals (CA), assailing the RTC Orders. The CA affirmed the RTC's findings, holding that there was valid service of the judgment to petitioners' counsel, relying on the postmaster's certification and the presumption of regularity. The CA denied petitioners' Motion for Reconsideration. Petitioners then filed a Petition for Certiorari with the Supreme Court, arguing grave abuse of discretion by the CA in affirming the RTC's finding of valid service and in ruling that their counsel was at fault.
Issue(s)
Whether there was a valid service of the RTC Decision dated March 7, 2002, to the petitioners' counsel. Whether the negligence of counsel binds the client, preventing the reopening of a final and executory judgment. Whether the Court of Appeals committed grave abuse of discretion in affirming the RTC's denial of due course to the Notice of Appeal.
Ruling
The petition is dismissed. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of valid service of the RTC Decision: The Court held that there was valid service of the RTC Decision to the petitioners' counsel. The Certification issued by the Postmaster General indicated that the copy of the judgment was duly delivered to the address on record of petitioners' counsel and was received by a security guard on March 15, 2002. The Court reiterated the rule that when a party appears by attorney, all notices must be given to the attorney of record. The receipt by the security guard, even if not directly by the counsel or their staff, constituted valid service under the circumstances, as the counsel was expected to have a system for receiving mail. On the issue of the negligence of counsel binding the client: The Court affirmed the principle that the negligence of counsel binds the client. The Court cited jurisprudence stating that clients are bound by the actions of their counsel in the conduct of their case, and that to allow otherwise would lead to endless litigation. The negligence of the counsel in monitoring mail or ensuring prompt receipt of communications is binding upon the client. The Court emphasized that the only exception is when the counsel's actuations are gross or palpable, resulting in serious injustice or deprivation of due process, which was not demonstrated in this case. Petitioners were given their day in court, and the judgment had become final and executory due to the failure to appeal within the reglementary period. On the issue of grave abuse of discretion: The Court found no grave abuse of discretion on the part of the Court of Appeals. The appellate court correctly affirmed the RTC's finding of valid service and the subsequent denial of due course to the Notice of Appeal. The petitioners' argument that the security guard was not authorized to receive mail was deemed insufficient to overcome the presumption of regularity in the performance of official duty by the postmaster. The Court stressed that litigation must end, and the doctrine of finality of judgment is grounded on public policy and sound practice, ensuring that judgments, once final, become immutable and unalterable.
Main Doctrine
The negligence of counsel binds the client, and a client cannot seek reversal of a final and executory judgment by merely invoking the counsel's mistake, unless the mistake is gross or palpable and results in serious injustice or deprivation of due process. Clients have a duty to monitor their cases and cannot solely rely on their counsel.