Edra v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a complaint for damages filed by Rosa N. Edra and her minor children against private respondents Marcelino T. Sadumiano (operator of a passenger jeepney) and Pepito Zambrana (the driver). The petitioners alleged that on April 15, 1981, they hired a jeepney for transport to Dingras, Ilocos Norte. During the journey on April 16, 1981, the driver, Pepito N. Zambrana, allegedly drove negligently, causing the jeepney to roll down a road and overturn, resulting in serious injuries, including burns, to the petitioners. They claimed significant damages for medical expenses, moral damages, exemplary damages, and attorney's fees due to the alleged negligence and abandonment. 2. Procedural History: The Court of First Instance of Rizal, after the private respondents failed to file an answer and were declared in default, rendered a decision on February 17, 1982, ordering the defendants to pay the plaintiffs jointly and severally. Private respondent Pepito M. Zambrana filed a motion to lift the order of default, claiming lack of jurisdiction due to improper service of summons and that the person who received it was nonexistent. This motion, along with a subsequent motion for reconsideration, was denied, and a writ of execution was ordered. A deputy sheriff attempted to enforce the writ but encountered difficulties identifying the correct respondent and locating assets. Subsequently, on February 10, 1986, private respondent Marcelino T. Sadumiano filed a petition for certiorari with the Intermediate Appellate Court (IAC), seeking to nullify the trial court's decision. The IAC, on April 16, 1986, set aside the trial court's decision and the writ of execution concerning Mario Sadumiano. The petitioners, who also failed to receive notice of the IAC's decision, discovered its issuance and were granted time to file a motion for reconsideration or appeal. 3. The Petition: This case reaches the Supreme Court via a petition for review on certiorari, challenging the decision of the Intermediate Appellate Court. The petitioners argue that the trial court had acquired jurisdiction over the person of the private respondent, Marcelino T. Sadumiano alias Mario T. Sadremiano, through proper service of summons. They contend that the IAC erred in setting aside the trial court's judgment, which had become final and executory. The core issue presented is whether the trial court indeed acquired jurisdiction over the person of the private respondent, asserting that the IAC's decision was contrary to established legal principles regarding the finality of judgments and the presumption of regularity in the performance of official duties by court officers.
Issue(s)
Whether the trial court acquired jurisdiction over the person of private respondent Marcelino T. Sadumiano alias Mario T. Sadremiano. Whether the decision of the trial court had become final and executory.
Ruling
The petition is granted. The appealed decision of the respondent Court of Appeals is reversed and set aside, and the judgment of the trial court dated February 17, 1982, is reinstated.
Ratio Decidendi
On the issue of jurisdiction over the person of private respondent Marcelino T. Sadumiano alias Mario T. Sadremiano: The Supreme Court held that the trial court acquired jurisdiction over the persons of the private respondents. The records showed that summons and a copy of the complaint were duly served upon the private respondents at their given addresses through Teofila Sadremiano, a person of sufficient age and discretion residing therein, as indicated in the Sheriff's Return dated July 22, 1981. The Court emphasized the presumption that a sheriff, as a public officer, regularly performs his official duties in the absence of contrary evidence. Furthermore, a copy of the trial court's decision was sent by registered mail to private respondent Sadremiano's correct address, and despite three notices, he failed to claim it. Service of the decision was deemed effective five days after the first notice of the postmaster, as per Section 8, Rule 13 of the Rules of Court. This established that the private respondents were properly notified of the proceedings and the decision. On the finality and executory nature of the trial court's decision: The Supreme Court ruled that the trial court's decision dated February 17, 1982, had become final and executory by operation of law. Private respondent Sadumiano received notice of the decision on March 2, 1982, and service was deemed complete five days thereafter. Within the 30-day period for appeal, he failed to file one. Consequently, by April 5, 1982, the judgment had attained finality. The Court reiterated the axiomatic principle that judgments which have long become final and executory can no longer be annulled or modified by the courts. The appellate court is deprived of jurisdiction to alter such final judgments. The doctrine of finality of judgments is grounded on fundamental considerations of public policy and sound practice, preventing the reopening of cases that have become final and executory. Therefore, the petition for certiorari filed by private respondent Sadumiano before the IAC on February 10, 1986, was an improper remedy, as certiorari is not a substitute for an appeal that has been lost. The Court concluded that the pleadings filed by the private respondent were intended to frustrate and defeat the execution of the judgment.
Main Doctrine
A judgment becomes final and executory by operation of law after the period for appeal has lapsed without one having been perfected. Judgments that have long become final and executory can no longer be annulled or modified by the courts, and the appellate court is deprived of jurisdiction to alter the trial court's final judgments. Certiorari is not a substitute for an appeal that has been lost.