Palma v. Petron
REITERATIONFacts
1. The Antecedents: Petitioners Adolfo C. Palma and Rafael Palma had been occupying a portion of Lot No. 257-A, a property leased by Petron Corporation (Petron) from the Philippine National Oil Company (PNOC), by mere tolerance since the early 1980s. In 2007, Petron informed the occupants, including the petitioners, that the area would be used for the construction of the Petron Skills Training Center and advised them to relocate. Despite a Final Notice to Vacate issued on August 8, 2008, petitioners refused to leave the premises. Consequently, Petron filed a complaint for unlawful detainer against them before the Municipal Trial Court (MTC) of Limay, Bataan. 2. Procedural History: The MTC ruled in favor of Petron on July 1, 2009, ordering petitioners to vacate the premises. Petitioners appealed to the Regional Trial Court (RTC), which dismissed the appeal on February 10, 2010, due to petitioners' failure to file an appellant's memorandum as required by the Rules of Court. A subsequent petition for relief filed by petitioners was also denied by the RTC. Petitioners then filed a petition for certiorari with the Court of Appeals (CA), which was dismissed for lack of merit on October 23, 2012, with the CA holding that petitioners had availed themselves of the wrong remedy. The CA denied their motion for reconsideration on July 1, 2013. Petitioners elevated the case to the Supreme Court (SC) via a petition for review on certiorari (G.R. No. 208052), which the SC denied on September 11, 2013. Their motion for reconsideration was denied with finality, and the resolution became final and executory on May 15, 2014. 3. The Petition: Despite the finality of the SC's resolution, petitioners filed a Petition for Annulment of Judgment with Application for a Temporary Restraining Order and/or Writ of Preliminary Injunction with the CA, seeking to annul the RTC Order dated February 10, 2010, and to restrain the execution and demolition orders. Petitioners argued that the RTC Order was issued without jurisdiction and that the MTC lacked jurisdiction over the unlawful detainer case due to the alleged failure to comply with the one-year filing period. The CA denied the petition on January 16, 2017, and subsequently denied the motion for reconsideration on April 20, 2017. The CA ruled that petitioners failed to comply with the conditions for annulment of judgment under Rule 47 of the Rules of Court, as the issues raised had already been passed upon in previous rulings, and petitioners had committed forum shopping. The present petition before the Supreme Court assails the CA's denial of the petition for annulment of judgment.
Issue(s)
Whether the Court of Appeals erred in denying petitioners' petition for annulment of judgment. Whether the Municipal Trial Court had jurisdiction over the unlawful detainer case. Whether petitioners are bound by the mistakes of their counsel.
Ruling
The petition is denied for lack of merit. The Decision dated January 16, 2017, and the Resolution dated April 20, 2017, of the Court of Appeals in CA-G.R. SP No. 143888 are affirmed.
Ratio Decidendi
On the denial of the petition for annulment of judgment: The Court reiterated the settled rule that a judgment, once final and executory, cannot be altered or modified, except under specific exceptions like clerical errors, void judgments, or circumstances rendering execution unjust. None of these exceptions applied here. The Court emphasized that a petition for annulment of judgment under Rule 47 is an equitable remedy that requires the petitioner to demonstrate that ordinary remedies like appeal or petition for relief were unavailable through no fault of their own. Petitioners' failure to file the appellant's memorandum before the RTC, despite ample opportunity, constituted negligence, making the remedy of annulment unavailable. Furthermore, the issues raised in the annulment petition had already been passed upon in previous certiorari and review petitions before the CA and the SC, respectively, indicating a pattern of seeking multiple avenues for relief on the same matters. On the jurisdiction of the Municipal Trial Court: The Court affirmed that jurisdiction is determined by the allegations in the complaint. Petron's complaint sufficiently alleged the elements of unlawful detainer: initial possession by tolerance, subsequent illegality of possession upon notice to vacate, continued possession despite notice, and the filing of the complaint within one year from the last demand. These allegations conferred jurisdiction on the MTC over the subject matter. The claim that the one-year period for filing was not met was belied by the allegations in the complaint, which stated that the complaint was filed within one year from the August 8, 2008 demand letter. Therefore, the ground of lack of jurisdiction for annulment of judgment was not met. On the mistakes of counsel: The Court reiterated the general rule that a client is bound by the mistakes of their counsel, even in procedural matters. An exception exists only when the counsel's gross negligence deprives the client of due process. In this case, the Court found that petitioners were not merely passive recipients of their counsel's alleged mistakes. Their own admission that petitioners' wife filed the memorandum in the wrong office demonstrated their active participation and negligence. Thus, they could not attribute their failure to file the memorandum solely to their counsel. The Court also clarified that a lawyer's neglect does not constitute extrinsic fraud, which must emanate from the adverse party and deprive the client of their day in court.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court is not a substitute for a lost remedy of appeal, and it cannot be availed of if the ordinary remedies, such as a motion for new trial, appeal, or petition for relief, were not availed of through no fault of the petitioner. Furthermore, a client is generally bound by the mistakes of their counsel, unless the counsel's gross negligence deprives the client of due process.