Dagot v. Key
REITERATIONFacts
The Antecedents: Petitioners, heirs of the late spouses Marcial Dagot, Sr. and Maxima Oblan, claimed ownership over a parcel of land registered under OCT No. G-558. Dagot, Sr. died in 1949. In 1960, the heirs and Oblan executed an Extra-Judicial Settlement with Sale, selling approximately 11 hectares to Pelagia P. Ebro. The original title could not be retrieved, so a reconstituted copy was used, with the sale annotated. Ebro later obtained TCT No. T-1220 for over 13 hectares. This property was subsequently sold to spouses Go Cheng Key and then donated to other respondents. Upon recovery of the original OCT No. G-558, it was discovered that prior annotations existed, indicating Oblan had sold four hectares to various individuals before the 1960 settlement. These sales, along with the sale to Ebro, accounted for the entire 17 hectares. Procedural History: Petitioners filed a complaint for reconveyance and annulment of titles on September 22, 1999, alleging that Ebro's title and subsequent titles exceeded the 11 hectares sold. The RTC initially ruled in favor of the petitioners, declaring Ebro's title void for the excess two hectares and ordering a new survey. Respondents moved for reconsideration. The RTC, in an Order dated November 10, 2009, treated respondents' "Urgent Manifestation" as a second motion for reconsideration, reversed its earlier decision, and dismissed the complaint, holding that the action had prescribed based on Article 1456 of the Civil Code and Section 52 of PD 1529. The Court of Appeals (CA) affirmed the dismissal, citing prescription. The CA denied petitioners' motions for reconsideration. The Petition: Petitioners filed two petitions for review on certiorari with the Supreme Court (G.R. No. 211309 and G.R. No. 211957), assailing the CA's decision. The Court expunged G.R. No. 211957 due to procedural infirmities and lack of authority from the petitioners. The Court then addressed the sole issue in G.R. No. 211309: whether the RTC's May 19, 2009 decision attained finality due to respondents' failure to appeal within the reglementary period.
Issue(s)
Whether the RTC's Decision dated May 19, 2009, attained finality for failure of the respondents to file an appeal within the reglementary period. Whether the "Urgent Manifestation" filed by the respondents, treated by the RTC as a second motion for reconsideration, could validly toll the reglementary period for appeal.
Ruling
The Supreme Court granted the Petition in G.R. No. 211309, set aside the CA's Decision and Resolution, and reinstated the RTC's Decision dated May 19, 2009. The petition in G.R. No. 211957 was expunged from the records. The affidavit and Sinumpaang Salaysay of Marcial O. Dagot, Jr. were ordered to be redocketed as a regular administrative complaint against Atty. Robert Y. Peneyra.
Ratio Decidendi
On the finality of the RTC's May 19, 2009 Decision: The Court ruled that the RTC's Decision dated May 19, 2009, had attained finality. The respondents received the Order denying their Motion for Reconsideration on November 4, 2009, giving them until November 19, 2009, to file an appeal. Instead, they filed an "Urgent Manifestation," which the RTC treated as a second motion for reconsideration. The Court emphasized that a second motion for reconsideration is expressly prohibited by Section 5, Rule 37 of the Rules of Court. Such a prohibited pleading cannot toll the running of the period to appeal because it has no legal effect. Therefore, the respondents' failure to file a proper appeal within the reglementary period meant the May 19, 2009 Decision became final and executory. The Court reiterated that the principle of immutability of judgments prevents alteration, amendment, or modification of a final and executory judgment, and none of the exceptions to this rule were applicable. On the validity of the "Urgent Manifestation" and tolling of the appeal period: The Court found that the "Urgent Manifestation" did not raise any new or substantial matter that would warrant an exception to the prohibition against second motions for reconsideration. The issues of prescription and implied trust were already raised in the respondents' earlier motion for reconsideration. The RTC's act of considering the "Urgent Manifestation" as a second motion for reconsideration, reversing its own decision, and tolling the appeal period was an error of law. The Court stressed that procedural rules must be faithfully observed, and the bare invocation of "interest of substantial justice" is insufficient to suspend them. Allowing such prohibited pleadings would lead to endless litigation and circumvent established procedures. The Court concluded that the "Urgent Manifestation" was a prohibited pleading and could not legally toll the period to appeal.
Main Doctrine
A prohibited second motion for reconsideration cannot toll the reglementary period for appeal, and failure to appeal within the reglementary period renders the judgment final and executory, barring any subsequent modification or alteration, except for recognized exceptions which do not apply in this case.