Public Estates Authority v. Yujuico
REITERATIONFacts
The Antecedents: Respondents Jesus S. Yujuico and Augusto Y. Carpio claimed ownership over two parcels of land along Roxas Boulevard, Parañaque City, evidenced by Transfer Certificates of Title (TCT) No. 446386 and TCT No. 44265, respectively. These lots were originally part of a consolidated title held by Fermina Castro. Petitioner, the Public Estates Authority (PEA), asserted ownership over adjacent lands acquired for the Manila-Cavite Coastal Road project, evidenced by Original Certificate of Title (OCT) No. SP 02 and TCT No. 7310. The core dispute arose when respondents alleged that the PEA's coastal road construction overlapped their property and that a portion of land sold by PEA to Manila Bay Development Corporation (MBDC) was also theirs. Respondents sought the annulment of PEA's and MBDC's titles, contending they were invalid, ineffective, or voidable. Procedural History: Respondents initiated Civil Case No. 96-0317 with a complaint for removal of cloud and annulment of title with damages. PEA denied the overlap, asserting its titles were government-granted. During the proceedings, PEA sought opinions from the Office of the Government Corporate Counsel (OGCC) and the Office of the Solicitor General (OSG), both of which upheld the validity of respondents' titles and found no grounds for reversion. PEA formed a committee that recommended an amicable settlement, leading to a compromise agreement approved by the trial court on May 18, 1998. This agreement involved an exchange of properties and an option for respondents to purchase additional land. However, PEA's new management sought a petition for relief from the trial court's approval, alleging mistake and excusable negligence due to the former General Manager's failure to secure the Office of the President's approval. The trial court dismissed this petition for being filed out of time and lacking merit. PEA's subsequent petition for certiorari before the Court of Appeals was also dismissed for failure to pay docket fees and for lack of merit, a decision affirmed upon reconsideration. The Petition: Petitioner PEA seeks review of the Court of Appeals' decision, arguing it committed errors of law and grave abuse of discretion. PEA contends it should be exempt from paying docket and legal fees as a government entity acting on behalf of the National Government, despite being an incorporated agency. It also argues that procedural technicalities should not bar it from seeking equitable relief, asserting the petition for relief was filed within a reasonable time given the circumstances. Furthermore, PEA claims fraud attended the execution of the compromise agreement, specifically the deletion of a required condition for Office of the President approval, constituting extrinsic fraud. The petition is filed under Rule 45 of the Rules of Civil Procedure.
Issue(s)
Whether PEA, as a government-owned or controlled corporation, is exempt from paying docket fees. Whether the petition for relief from judgment was filed within the reglementary period. Whether fraud attended the execution of the compromise agreement.
Ruling
The petition is denied. The Court of Appeals' decision is affirmed. The temporary restraining order is lifted.
Ratio Decidendi
On the issue of exemption from docket fees: The Court held that while the Republic of the Philippines and its agencies and instrumentalities are exempt from paying legal fees, local governments and government-owned or controlled corporations (GOCCs) with or without independent charters are not exempt. PEA, created by Presidential Decree No. 1084, is a GOCC wholly owned by the government. Although it has a separate juridical personality, it remains an agent or instrumentality of the government. However, Section 19, Rule 141 of the Revised Rules of Court explicitly states that GOCCs are not exempt. The Court clarified that while failure to pay docket fees may give the court discretion to dismiss a case, it does not preclude cognizance if the ends of justice warrant it. Nevertheless, PEA, as a GOCC, is not automatically exempt from paying docket fees. On the timeliness of the petition for relief: The Court affirmed the findings of the lower courts that the petition for relief was filed out of time. The trial court approved the compromise agreement on May 18, 1998. Subsequent hearings were held on June 1, 1998, and July 2, 1998, where parties manifested their actions based on the compromise agreement, leading to the dismissal of claims with prejudice on July 3, 1998. The petition for relief was filed on September 14, 1998. Rule 38, Section 3 of the 1997 Rules of Civil Procedure requires filing within sixty (60) days after the petitioner learns of the judgment and not more than six (6) months after entry. The Court found that PEA, through its previous counsel, was aware of the May 18, 1998 resolution well before July 15, 1998, making the September 14, 1998 filing beyond the 60-day period. A change in management does not excuse compliance with reglementary periods. On the issue of fraud: The Court found no sufficient basis to consider the alleged inadvertence as extrinsic fraud. The compromise agreement was entered into after an in-depth study by PEA's special committee, with opinions from the OGCC and OSG supporting the validity of respondents' titles and recommending settlement. The alleged omission of the Office of the President's approval requirement was not sufficiently proven as extrinsic fraud that prevented PEA from presenting its case. The Court also noted that the issue of fraud was raised for the first time on appeal, which is generally not allowed. The Court also declined to pass upon the issue of whether the property was still under water when titled, as it was beyond the scope of the petition and not previously ventilated.
Main Doctrine
A government-owned or controlled corporation, even if vested with a separate juridical personality, is not exempt from paying docket fees unless it falls under the specific exemptions provided by law. Furthermore, a petition for relief from judgment must be filed within the reglementary period, and mere change of management or alleged inadvertence without sufficient proof of fraud, accident, mistake, or excusable negligence does not justify its late filing.