Roxas v. Cruz
REITERATIONFacts
The Antecedents: Francisca Roxas filed an action for the recovery of a sum of money against Tirso Cruz, Silverio Cruz, and Simeon Cruz. The sheriff of Manila certified that summons and complaint were served by leaving copies at the defendants' usual place of residence with Josefa Cruz, wife of Tirso Cruz and sister-in-law of the other defendants, who was of sufficient discretion to receive them. Attorney G. T. Antaran appeared for the defendants and filed an answer. Subsequently, the parties, through their respective attorneys, agreed to a judgment ordering the defendants to pay P3,000 jointly and severally, with interest. The court rendered judgment accordingly. A writ of execution was issued, and mortgaged property was sold at public auction to the plaintiff Francisca Roxas for P1,500. The sale was confirmed, and an alias execution was ordered for the balance of P1,684.86. A certificate of sale was issued to the plaintiff. Procedural History: Silvino Cruz and Simeon Cruz filed a petition to annul the judgment and its execution, alleging they were not summoned, had no knowledge of the case, and did not authorize Attorney Antaran to represent them or enter into an agreement. The trial court denied this petition. The Petition: The defendants Silvino Cruz and Simeon Cruz appealed the denial of their petition to annul the judgment and execution.
Issue(s)
Whether a judgment that appears legal and final on its face can be attacked via a summary petition for annulment on the ground of lack of jurisdiction over the parties sixteen months after its rendition.
Ruling
The Supreme Court affirmed the resolution of the lower court denying the petition for annulment. The Court held that the judgment, on its face, appeared to be legally rendered with jurisdiction and was final. The challenge to the judgment's validity on the ground of lack of jurisdiction over the parties could not be made through the collateral proceeding filed, but must be attacked directly. Furthermore, the petition was filed after the lapse of sixteen months from the rendition of the judgment, and remedies such as appeal, new trial, or relief under Section 113 of the Code of Civil Procedure were not availed of within the prescribed periods.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the judgment, on its face, was legally rendered with jurisdiction and had already reached finality. The Court observed that the appellants failed to utilize the available procedural remedies, such as filing an appeal, seeking a new trial, or availing of the relief provided under Section 113 of the Code of Civil Procedure (CCP), which allows relief from judgments taken through mistake or excusable neglect. By waiting sixteen months to file their petition, the appellants allowed the judgment to become immutable. Citing the case of Banco Español-Filipino vs. Palanca (37 Phil., 921), the Court held that a challenge to a judgment's validity based on lack of jurisdiction over the parties is a matter of evidence that cannot be determined in a summary motion once the judgment is final. The Court clarified that since the record shows a valid return of summons and an appearance by counsel, there is a presumption of jurisdiction that the court must uphold. If the appellants wish to contest these facts—specifically the lack of summons or the unauthorized nature of the attorney's appearance—they must do so through a direct action specifically intended to attack the resolution. Consequently, the summary petition was not the correct vehicle to challenge the final judgment, and the lower court's denial was legally sound.
Main Doctrine
A judgment rendered by a court with jurisdiction over the parties and the subject matter, which has become final, cannot be attacked collaterally on the ground of lack of jurisdiction over the parties; such a challenge must be brought directly. The remedy provided by Section 113 of the Code of Civil Procedure must be availed of within the prescribed period.