Heirs of Mendoza v. J.A. Development Corp.
REITERATIONFacts
1. The Antecedents: J.A. Development Corporation (JADC) filed an unlawful detainer complaint against Benjamin Mendoza and others, asserting ownership over several lots in Tagaytay City based on a 1992 purchase. JADC claimed that the occupants, previously tolerated by the predecessor-in-interest, refused to vacate even after JADC informed them of its ownership and offered P50,000.00. A kasunduan (agreement) was executed on August 26, 1994, where Benjamin Mendoza acknowledged JADC's ownership, but the occupants still did not vacate, requesting to stay until JADC needed the property. When JADC demanded the property for development in 1999, the occupants refused, disavowed the kasunduan, allowed strangers to occupy the property, and ignored demand letters dated October 29, 1999, and December 2, 2000. 2. Procedural History: Benjamin Mendoza, in his answer, claimed ownership of the property as an heir of equitable owners under the Friar Land Act, asserting that JADC's titles were void. He also cited an ongoing case (Civil Case No. TG-1904) before the Regional Trial Court (RTC) for quieting of title, where a partial decision allegedly recognized his rights, arguing for litis pendentia. The Municipal Trial Court in Cities (MTCC) dismissed JADC's unlawful detainer complaint for lack of jurisdiction, finding the issue of possession inseparable from the issue of ownership. The RTC affirmed the MTCC's decision. The Court of Appeals (CA) reversed the RTC, remanding the case to the MTCC, ruling that the prior RTC case could not abate the ejectment action. The CA subsequently denied the petitioners' motion for reconsideration, which argued they were not furnished a copy of the petition for review. 3. The Petition: The petitioners, heirs of Benjamin Mendoza, filed a Petition for Review with the Supreme Court, primarily arguing that the Court of Appeals lacked jurisdiction due to a denial of due process. They contended that JADC failed to serve a copy of the petition for review on their counsel of record, Atty. Sergio F. Angeles, instead serving it on Benjamin Mendoza himself. This procedural defect, they argued, rendered the CA proceedings and its subsequent decision void. The Supreme Court, finding that the lack of notice to counsel deprived the petitioners of due process, reversed and set aside the CA's decision and resolution, remanding the case to the CA for further proceedings.
Issue(s)
Whether the service of the petition for review and subsequent CA notices on the party himself, instead of his counsel of record, is valid under Rule 13. Whether the petitioners were deprived of due process, rendering the CA decision and the subsequent Entry of Judgment void.
Ruling
The Supreme Court REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals and REMANDED the case to the Court of Appeals for further proceedings.
Ratio Decidendi
On the Issue of Service of Pleadings: The Court ruled that the service was invalid. Applying Section 2, Rule 13 of the 1997 Rules of Civil Procedure, the Court held that when a party is represented by counsel, service must be made upon the counsel unless the court orders otherwise. The records showed that Atty. Sergio F. Angeles was the counsel of record for Benjamin Mendoza in both the MTCC and RTC. JADC's act of serving the petition for review on Mendoza personally, and the CA's subsequent service of resolutions and the decision on Mendoza instead of his counsel, constituted a 'nullity' in law. The Court reiterated that notice to the client and not to his counsel of record is not notice in law. On the Issue of Due Process: The Court found that the lack of notice to petitioners' counsel deprived them of the opportunity to participate in the CA proceedings. This procedural defect is not merely technical but goes to the heart of the right to due process. The Court emphasized that the conclusion of deprivation of due process is 'inescapable' when a party is not properly notified through their legal representative. Consequently, the CA decision could not have become final and executory, and the Entry of Judgment was premature. To serve the ends of justice, the case must be remanded to the CA to allow the petitioners to ventilate their arguments regarding the MTCC's jurisdiction over the unlawful detainer case.
Main Doctrine
The doctrine emphasizes the mandatory nature of serving pleadings and court notices to the counsel of record rather than the party. Under the Rules of Court, once a party is represented by counsel, the lawyer becomes the agent for service of all legal processes. This rule ensures that legal matters are handled by trained professionals and protects the party's right to due process. Any service made directly to the party, without a specific court order, is legally non-existent and cannot trigger the running of prescriptive periods or the finality of judgments.