Duremdes v. Jorilla
REITERATIONFacts
The Antecedents: Respondents filed a Complaint for Collection of Sum of Money plus Damages against petitioner and another individual, alleging they were victims of illegal recruitment by a corporation in which the petitioner was a majority stockholder. The Regional Trial Court (RTC) rendered a decision awarding damages to the respondents after the petitioner and his co-defendant failed to file an answer or any responsive pleading, having been declared in default. The RTC noted that summons was served upon the petitioner by publication. Procedural History: Following the RTC's decision, the petitioner filed a Petition for Relief from Judgment, seeking to annul the decision based on alleged fraud, specifically that respondents provided an erroneous address for service of summons, thereby preventing him from presenting his case and depriving the RTC of jurisdiction over his person. The RTC denied this petition for lack of merit and ordered the issuance of a writ of execution. The petitioner then filed a Petition for Certiorari with the Court of Appeals (CA), which the CA dismissed due to several procedural infirmities, including the failure to attach essential documents and the improper availment of a petition for relief instead of an appeal. The CA's dismissal was affirmed upon denial of the petitioner's motion for reconsideration. The Petition: The petitioner seeks a review on certiorari under Rule 45 of the Rules of Court, challenging the CA's dismissal of his petition for certiorari. The petitioner argues that the CA erred in dismissing his case on technicalities, asserting substantial compliance with procedural requirements through subsequent submissions. He also contends that the CA should not have dismissed his petition for relief from judgment without considering the merits, as the alleged extrinsic fraud, if proven, would render the RTC's judgment void for lack of jurisdiction over his person, making the judgment assailable at any time. The Supreme Court, in its decision, found merit in the petition and remanded the case to the CA for a determination of the merits of the petitioner's certiorari petition.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari based on technicalities. Whether the petition for relief from judgment was the proper remedy despite the availability of appeal. Whether the RTC Decision dated March 20, 2014, is void for lack of jurisdiction over the person of the petitioner due to alleged extrinsic fraud in the service of summons.
Ruling
The Supreme Court granted the petition, reversed and set aside the CA Resolutions, and remanded the case to the CA for determination of the merits of the petition for certiorari. The Court found that the CA should not have been too rigid in dismissing the petition based on technicalities, as the petitioner's subsequent submissions to the CA constituted substantial compliance. Furthermore, the Court held that a petition for relief grounded on extrinsic fraud that results in a lack of jurisdiction over the defendant renders the judgment void and assailable anytime, making the issues of appeal and timeliness intertwined with the merits of the case.
Ratio Decidendi
On the CA's dismissal based on technicalities: The Court ruled that the CA erred in dismissing the petition for certiorari based solely on technicalities. Citing Jaro v. Court of Appeals and Air Philippines Corp. v. Zamora, the Court emphasized that rules of procedure should not be used to defeat justice. The petitioner's subsequent submission of required documents with his Motion for Reconsideration before the CA was considered substantial compliance with the formal requirements under Section 1 of Rule 65 of the Rules of Court. The Court noted that the CA should have considered these submissions rather than being overly rigid. On the propriety of availing a petition for relief despite failure to appeal: The Court held that the CA erred in dismissing the petition for certiorari based on the petitioner's failure to explain why he did not appeal. The Court clarified that when a petition for relief is grounded on extrinsic fraud that allegedly resulted in the court's lack of jurisdiction over the defendant, the issues of appeal availability and the propriety of the petition for relief are intertwined with the merits of the case. The Court stated that these issues could only be resolved by examining the substance of the petitioner's arguments regarding the alleged fraud and lack of jurisdiction. On the void nature of the RTC Decision due to lack of jurisdiction: The Court explained that jurisdiction over a defendant in an action in personam is acquired through valid service of summons or voluntary appearance. If the service of summons is defective, the court acquires no jurisdiction over the person, and any judgment rendered is null and void. The Court found that if the petitioner's allegations of extrinsic fraud in the service of summons were true, the RTC would have lacked jurisdiction over his person, rendering the RTC Decision dated March 20, 2014, void. A void judgment can be attacked anytime and does not acquire finality, thus an action to declare its nullity does not prescribe, nor is it subject to the strict time periods for a petition for relief or barred by laches or estoppel. Therefore, the CA should not have dismissed the petition for certiorari on the grounds of untimeliness or failure to appeal.
Main Doctrine
A petition for relief grounded on extrinsic fraud that negates the court's jurisdiction over the defendant may be filed anytime, as it renders the judgment void and assailable at any point, not being subject to the strict time periods for petitions for relief or barred by laches or estoppel.