Thomas v. Trono
REITERATIONFacts
1. The Antecedents: Earl Alphonso Thomas, an American citizen, married Rachel Trono on October 7, 1984. Their marriage was declared void ab initio by the Regional Trial Court (RTC) on August 22, 1997, due to bigamy, as Alphonso was still married to Nancy Thomas. During the nullity proceedings, Alphonso and Rachel agreed that properties acquired during their marriage would go to Rachel and their son, Earl James Thomas. Subsequently, Alphonso cohabited with Jocelyn C. Ledres, with whom he had a child, Charnnel Shane Thomas, born on August 21, 1998. Alphonso and Jocelyn married on July 22, 2007. 2. Procedural History: Following Alphonso's death on February 12, 2011, Jocelyn sought copies of the August 22, 1997 RTC Decision. It was discovered that the Republic, through the Office of the Solicitor General (OSG), had not been furnished a copy. The RTC provided the OSG with a copy, allowing 15 days to appeal or seek reconsideration. The OSG filed a motion for reconsideration on March 28, 2011, arguing that Alphonso's prior marriage was not sufficiently proven and that it was not properly notified of the proceedings. Jocelyn, by counsel, filed a Manifestation and Special Appearance, informing the court of Alphonso's death and her marriage to him, and asserting the validity of the August 22, 1997 Decision. On June 28, 2011, the RTC granted the OSG's motion, reversed its earlier decision, and declared the marriage between Alphonso and Rachel valid and subsisting. Charnnel, as an heir of Alphonso, filed a petition for annulment of judgment with the Court of Appeals (CA) on September 13, 2017, alleging denial of due process, specifically noting the OSG's motion was belatedly filed and that she was not notified. The CA dismissed Charnnel's petition on October 10, 2017, ruling that the RTC retained jurisdiction and that Charnnel was not denied due process as Jocelyn had participated. Charnnel's motion for reconsideration was denied on July 26, 2018. 3. The Petition: Charnnel Shane Thomas filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's dismissal of her petition for annulment of judgment. She argues that she was denied due process because she was not notified of the OSG's motion for reconsideration before the RTC, which led to the reversal of the August 22, 1997 Decision declaring her parents' marriage void. Charnnel contends that the OSG's motion for reconsideration was filed beyond the reglementary period, rendering the August 22, 1997 Decision final and that the RTC consequently lost jurisdiction to act on the belated motion. The OSG, in its counter-argument, maintains that due process was observed as Jocelyn, Charnnel's mother, was able to file a manifestation and special appearance.
Issue(s)
Whether Charnnel, as an heir of Alphonso, has legal standing to assail the RTC's Order dated June 28, 2011. Whether the RTC committed a denial of due process against Charnnel. Whether the RTC retained jurisdiction to rule on the OSG's motion for reconsideration and reverse its August 22, 1997 Decision.
Ruling
The petition is meritorious. The Resolutions dated October 10, 2017 and July 26, 2018 of the Court of Appeals are reversed and set aside. A new judgment is rendered ordering the granting of petitioner Charnnel Shane Thomas' petition for annulment of judgment. The Decision dated August 22, 1997 of the Regional Trial Court of Makati City, Branch 140 is reinstated.
Ratio Decidendi
On the legal standing of Charnnel: Charnnel, as an heir of Alphonso, possesses the legal standing to assail the marriage of Alphonso and Rachel by seeking the annulment of the RTC's Order dated June 28, 2011. Void marriages, governed by the New Civil Code, can be questioned even after the death of either party, as the deceased may have heirs with legal standing to assail the void marriage. The records show Charnnel was neither a party nor duly notified of the proceedings, and she was a minor at the time the RTC granted the OSG's motion. While Jocelyn filed a Manifestation and Special Appearance, it did not directly raise or thresh out Charnnel's interests as Alphonso's heir, thus not binding her and potentially depriving her of due process. On the denial of due process against Charnnel: Charnnel was denied due process because she was not made a party to the proceedings nor duly notified of the case, especially considering she was a minor at the time the RTC granted the OSG's motion. Although her mother, Jocelyn, filed a pleading, it did not adequately represent Charnnel's specific interests as an heir. The fundamental right of due process requires that persons with an interest in the subject matter be notified and afforded an opportunity to defend their interests. A decision rendered in disregard of this right is void for lack of jurisdiction. On the jurisdiction of the RTC to rule on the OSG's motion for reconsideration: The RTC lost jurisdiction to rule on the OSG's motion for reconsideration and reverse its August 22, 1997 Decision because the motion was belatedly filed. The OSG received the Decision on March 8, 2011, and had until March 23, 2011, to file its motion. However, the motion was filed on March 28, 2011, beyond the 15-day reglementary period. Consequently, the August 22, 1997 Decision became final and executory by operation of law. A judgment that has attained finality can no longer be altered, amended, or modified, as the principle of immutability of judgments dictates that litigation must come to an end.
Main Doctrine
A petition for annulment of judgment based on denial of due process is granted when a party, as an heir, was not notified of proceedings that affected their rights, and when a court reverses a final and executory judgment due to a belatedly filed motion for reconsideration, thereby losing jurisdiction.