Villarica v. Sison
REITERATIONFacts
1. The Antecedents: Margarita Villarica initiated a civil case against Andrea Cuison. The parties subsequently submitted a stipulation of facts, wherein the defendant confessed judgment for P5,000.00 in principal, P1,100.00 in interest, and P200.00 in attorney's fees, totaling P6,300.00. The stipulation also stated that judgment would not be entered until January 15, 1934, and that this judgment would be final. 2. Procedural History: On August 24, 1933, the respondent judge, Pedro Ma. Sison, approved the stipulation and ordered compliance. The parties were notified on August 26, 1933, and no objections or appeals were filed. However, on January 11, 1934, Lemerina Paralejo Tuason and others filed a motion to set aside the decision and intervene as third-party claimants. Respondent Judge Sison granted this motion on March 10, 1934, despite petitioner's opposition. Petitioner's subsequent motion to set aside this order was denied by respondent Judge Antonio Horrilleno on September 18, 1934. A motion for reconsideration was then denied by respondent Judge Manuel V. Moran on September 29, 1934. 3. The Petition: Margarita Villarica filed an original petition for certiorari seeking to annul the orders dated March 10, September 18, and September 29, 1934, issued in civil case No. 44406. The petitioner argues that the respondent judges acted without jurisdiction. Specifically, she contends that the August 24, 1933 decision, based on the parties' stipulation, had become final and executory after thirty days, divesting Judge Sison of jurisdiction to set it aside. Furthermore, she argues that allowing intervention and third-party claims after the judgment had become final also exceeded the court's jurisdiction.
Issue(s)
Whether the respondent judges exceeded their jurisdiction in setting aside the decision dated August 24, 1933, after more than thirty days had elapsed from the date of notification. Whether the respondent judge had jurisdiction to permit the respondents to intervene in civil case No. 44406 and to file a third-party claim after the judgment had become final.
Ruling
The Supreme Court granted the petition and declared the orders dated March 10, September 18, and September 29, 1934, issued by respondent judges Pedro Ma. Sison, Antonio Horrilleno, and Manuel V. Moran, respectively, null and void. The preliminary injunction issued was made final.
Ratio Decidendi
On the issue of exceeding jurisdiction in setting aside the decision: The Court held that the decision rendered on August 24, 1933, based on the parties' compromise, became final after the lapse of thirty days from the date of notification on August 26, 1933, without any motion for a new trial or appeal being filed. Consequently, respondent Judge Pedro Ma. Sison was deprived of his jurisdiction to amend, alter, or revoke the said decision. The subsequent order setting aside this final decision was therefore issued without jurisdiction. The Court noted that the parties' conduct, including the respondents' motion to set aside the decision, indicated their understanding that a decision had indeed been rendered on August 24, 1933. On the issue of jurisdiction to permit intervention and third-party claim: The Court ruled that Section 121 of Act No. 190 allows intervention at any period of a trial if a person has a legal interest. However, in this case, the motion for intervention was filed 156 days after notification of the decision and 126 days after it became final. Since the judgment had already become final and the court had lost jurisdiction over it, respondent Judge Pedro Ma. Sison acted without jurisdiction in permitting the respondents to intervene and file a third-party claim. The Court emphasized that intervention is permissible during the trial, but not after the judgment has become final and executory.
Main Doctrine
The Supreme Court held that a judge who permits a person to intervene in a civil case and file a third-party claim therein after the judgment has become final exceeds his jurisdiction. Such an order is null and void because the court loses jurisdiction over the case once the judgment has become final and executory, and no longer has the authority to amend, alter, or revoke it.