Montehermoso v. Batuto
REITERATIONFacts
The Antecedents: Respondents Romeo and Arnel Batuto initiated a legal action seeking the cancellation of title, reconveyance, and damages. They alleged that their property, a parcel of land measuring forty-four thousand four hundred ten square meters (44,410 sq.m.), was erroneously included in OCT No. 5781, registered under the names of petitioners Marilyn B. Montehermoso, Tanny B. Montehermoso, Emma B. Montehermoso Oliveros, Eva B. Montehermoso, Teresa B. Montehermoso Carig, and Salvar B. Montehermoso. The Regional Trial Court (RTC), in a Decision dated March 8, 2015, found merit in the respondents' claims and ordered the reconveyance of the property. Procedural History: Following the RTC's Decision, petitioners engaged in a series of legal challenges. Their initial appeal to the Court of Appeals was dismissed by Resolution dated August 5, 2016, which became final and executory on September 9, 2016, leading to the issuance of writs of execution and demolition. Subsequently, Petitioner Tanny Montehermoso filed a petition for relief from judgment, which was also dismissed by the Court of Appeals in a Resolution dated September 27, 2017, with a subsequent denial of the motion for reconsideration on April 24, 2018. A petition for review on certiorari to the Supreme Court was denied on August 6, 2018. Undeterred, petitioners filed a petition for annulment of judgment with the Court of Appeals, alleging lack of jurisdiction, which was dismissed by Resolution dated February 13, 2019, and further denied reconsideration on April 10, 2019. The Petition: Petitioners have once again filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' Resolutions dated February 13, 2019, and April 10, 2019, which denied their petition for annulment of judgment. The petitioners have persistently attacked the March 8, 2015 RTC Decision, which attained finality on September 9, 2016, through various legal avenues over a period of more than five years, despite the clear and indisputable absence of any right calling for vindication and the implementation of the judgment. The Supreme Court denied the petition, affirming the Court of Appeals' resolutions and sternly warning petitioners and their counsel against any further attempts to revive the case.
Issue(s)
Whether the petitioners' repeated attempts to assail the March 8, 2015 RTC Decision, which had long attained finality, constitute forum shopping and violate the doctrine of immutability of judgment. Whether the Court of Appeals erred in dismissing the petition for annulment of judgment.
Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the Resolutions of the Court of Appeals dated February 13, 2019, and April 10, 2019. Petitioners and their counsel were sternly warned that any further attempt to revive the case in whatever form and before any forum will be severely sanctioned.
Ratio Decidendi
On the issue of immutability of judgment and forum shopping: The Court reiterated the doctrine of immutability of judgment, stating that a decision that has acquired finality becomes immutable and unalterable. The petitioners, by filing multiple actions and appeals over five years, have persistently attacked a decision that had long become final and executory. This conduct demonstrates a clear disregard for the principle of finality of judgment and constitutes an abuse of the judicial process. The Court emphasized that every litigation must come to an end, and litigants should not be granted an unbridled license to come back for another try once their rights have been adjudicated in a valid and final judgment. The repeated filing of actions to set aside a final and executory judgment, without any valid grounds such as fraud, mistake, or excusable negligence, is considered forum shopping and a violation of the principle of res judicata. The Court noted that the respondents have suffered injustice due to the undue delay in the execution of the final judgment in their favor. The Court also reminded petitioners' counsel of their duty as officers of the court to advise clients on the merit of their cases and to resist their propensity to litigate when a cause is defenseless, as their oath to uphold justice is superior to their duty to their client. On the issue of the Court of Appeals' dismissal of the petition for annulment of judgment: The Court found no reversible error in the CA's dismissal of the petition for annulment of judgment. The grounds raised by the petitioners, particularly the alleged lack of jurisdiction of the trial court, were already deemed settled by the finality of the original decision and the subsequent dismissals of their appeals and petitions. The CA correctly applied the doctrine of immutability of judgment in dismissing the petition for annulment. The Court reiterated that the time of the judiciary is too valuable to be wasted by efforts to evade the operation of a decision that is final and executory, especially when there is a clear absence of any right calling for vindication. The Court viewed with disfavor the unjustified delay in the enforcement of the final decision and orders, stating that such delays set at naught the role of courts in disposing justiciable controversies with finality.
Main Doctrine
A judgment that has attained finality becomes immutable and unalterable, and any subsequent attempt to assail it through various legal remedies, absent any showing of fraud, mistake, or excusable negligence that would warrant an annulment of judgment, constitutes forum shopping and trifles with the judicial process, warranting the denial of such attempts and stern warning against further litigation.