Pinlac v. Court of Appeals
REITERATIONFacts
The Antecedents: The dispute centers on 502 hectares of land in Old Balara, Sitio Veterans, Barrio Payatas and Silangan, Quezon City, claimed by petitioners—World War II veterans, dependents, and successors—as public forest land occupied continuously, adversely, and exclusively for over 30 years via the World War II Veterans Legionnaires of the Philippines, Inc., with tacking of possession; they filed applications for titling. Petitioners impleaded titled owners, including Vil-Ma Maloles Subdivision Inc. (Vil-Ma), but not individual lot owners within Vil-Ma, alleging mother titles like OCT No. 614, TCT No. 5690 (Jose V. Bagtas, fraudulently expanded from 294.6 sqm to 23.5767 has.), TCT No. 3548 (Vil-Ma, spurious, no technical description, from nowhere), and OCT No. 333 (expanded from 4,574 sqm to 407.3875 has.) were void ab initio due to fraud, lack of descriptions, and mismatch in locations (e.g., TCTs covering Ermitaño, Talipapa, etc., claimed over litigated area). Bureau of Forest Development certified lands as public forest not alienable, yet tolerated petitioners' occupancy with residential permits and MERALCO aid. Private respondents, individual titled owners in Vil-Ma (derived from Piedad Estate friar lands under OCT 614, valid per De La Cruz v. De La Cruz and Ad Hoc Committee), learned of case only upon execution attempts. Vil-Ma dissolved January 26, 1976 per SEC certificate, lots sold to individuals pre-1983 complaint. Procedural History: Petitioners filed class suit for Quiet Title (Civil Case No. Q-35672, RTC Quezon City Br. 83, Nov. 2, 1983); summons by publication ordered May 5 & Sept. 29, 1983 in 'Metropolitan Newsweek' (Caloocan-Malolos local paper), not Quezon City general circulation. Some respondents answered; Vil-Ma et al. defaulted; ex parte evidence led to Partial Decision (Mar. 21, 1988) declaring petitioners owners via 30-year extraordinary prescription (presuming agricultural despite forest cert.), nullifying OCT 614, TCTs 5690/3548/333 & derivatives (except non-defaulted), ordering cancellations/TCT issuance, perpetual injunction. Vil-Ma lot owners filed Petition for Annulment of Judgment w/ Certiorari/Prohibition/Mandamus (CA-G.R. SP No. 17596, May 17, 1989), alleging no jurisdiction, extrinsic fraud, due process denial; CA issued injunction (Jun. 23, 1989), then Decision (Nov. 15, 1989) annulling Partial Decision for defective publication/lack of jurisdiction over persons/properties, Vil-Ma non-existence; MR denied Dec. 21, 1989. The Petition: Petitioners sought certiorari (G.R. No. 91486) assailing CA for ignoring their answers' issues (due process violation), claiming jurisdiction via publication on court order, arguing private respondents' contradictory positions (claiming friar lands validity yet forest expansion) voided CA action; insisted Partial Decision valid as Vil-Ma bound subdivision owners.
Issue(s)
Whether the CA violated petitioners' due process by ignoring issues in their CA answer. Whether RTC acquired jurisdiction over Vil-Ma via publication, validating Partial Decision. Whether private respondents had valid cause before CA given contradictory theories.
Ruling
The petition is DENIED for lack of merit; CA Decision in CA-G.R. SP No. 17596 AFFIRMED, annulling RTC Partial Decision for lack of jurisdiction and denial of due process.
Ratio Decidendi
On Issue 1 (CA ignoring petitioners' answers): Annulment of judgment under Rule 47 grounds (extrinsic fraud/lack of jurisdiction/denial of due process) requires no merits retrial, only proof of vitiating defects to renew litigation (Straits Times v. CA, 294 SCRA 714; Salonga v. CA, 269 SCRA 534; Ybanez v. CA, 253 SCRA 540); CA properly focused thereon without addressing factual merits like prescription/forest classification/titles' validity, as purpose is setting aside executory judgment for new trial (I Moran, Rules of Court, citing Anuran v. Aquino, Banco Español v. Palanca); no due process violation to petitioners, who had their ex parte day, but to respondents denied notice. On Issue 2 (Jurisdiction via publication): Publication in 'Metropolitan Newsweek' (local Caloocan-Malolos) defective under Rule 14, Sec. 14 & P.D. 1079, Sec. 1 requiring Quezon City general circulation newspaper; court orders (May 5/Sept. 29, 1983) lacked specifics on place/time, fatal defect (Gan Hock v. CA, 197 SCRA 223; Sahagun v. CA, 198 SCRA 44; Paluwagan v. King, 172 SCRA 60); even if proper, Vil-Ma dissolved 1976 (SEC cert.), lost juridical personality, suing it binds no individual lot owners (indispensable parties per prayer nullifying their TCTs); blatant due process denial, as owners uninformed of title-nullifying proceedings (Republic v. Sandiganbayan, 266 SCRA 515; Fabella v. CA, 282 SCRA 256). On Issue 3 (Private respondents' cause/contradictions): Irrelevant to annulment's narrow grounds; default judgments disfavored (Trajano v. Cruz, 80 SCRA 712; Lesaca v. CA, 215 SCRA 17), yield to equity/new trial (Sps. Ameloquio v. CA, G.R. 124243; Gerales v. CA, 218 SCRA 638); Rule 10, Sec. 5(c) violated—common cause vs. all respondents required trial on answering defenses inuring to defaulted (OCT 614 validity for all or none); pre-judged merits against answerers.
Main Doctrine
Service of summons by publication must strictly comply with Rule 14, Section 14 of the Rules of Court, requiring publication in a newspaper of general circulation in the place where the action is filed or property located, such as Quezon City in this case; failure to do so, as when published in a local Caloocan-Malolos periodical, results in lack of jurisdiction over the person, rendering the default judgment void. Even if publication were proper, suing a dissolved juridical entity (Vil-Ma Subdivision, dissolved in 1976) does not bind its successor individual lot owners, who are indispensable parties and must be impleaded individually in actions seeking to nullify their Torrens titles. An action for annulment of judgment is proper on grounds of lack or want of jurisdiction or denial of due process, without need to retry merits, as it seeks to reopen litigation for fairness. Under Rule 10, Section 5(c), in cases with common cause of action against multiple defendants, where some answer and others default, the court must try the case against all based on answering defendants' evidence, with their defenses inuring to defaulted co-defendants. Judgments by default are disfavored and must not deprive registered owners of property without notice and hearing, upholding constitutional due process as a cornerstone against positive injustice.