Sandejas v. Robles
REITERATIONFacts
The Antecedents: Plaintiff-appellant Jose P. Sandejas filed an action against defendants-appellees Zacarias C. Robles, Elena C. Vda. de Robles, and Rosario Y. Singson. The case involved the performance or non-performance of the terms and conditions of a contract of sale for the enforcement or resolution thereof concerning three parcels of land. Procedural History: The Court of First Instance of Iloilo dismissed the plaintiff's action upon motion of the defendants, holding that it was barred by a prior judgment. The prior judgment, rendered on October 2, 1944, during the Japanese occupation, resolved the contract of sale and ordered the appellees to return P5,723.60 to the appellants. The appellants had submitted to the jurisdiction of the court by filing an answer through their attorney. Although notified of the hearing, their attorney withdrew his appearance, citing difficulty in communicating with his clients. The hearing was postponed, but the appellants did not appear, leading to the judgment. A motion for reconsideration was denied, and an appeal was also denied. The Petition: The plaintiff-appellant appealed the dismissal, contending that the court that rendered the prior judgment lacked jurisdiction and that the judgment was rendered in violation of due process, depriving him of his day in court.
Issue(s)
Whether the Court of First Instance of Iloilo had jurisdiction to render the judgment on October 2, 1944, during the Japanese occupation. Whether the prior judgment was rendered in violation of the due process clause, depriving the plaintiff of his day in court.
Ruling
The appeal is dismissed. The judgment of the Court of First Instance of Iloilo is upheld.
Ratio Decidendi
On the issue of jurisdiction: The appellants' contention that the Court of First Instance of Iloilo lacked jurisdiction over the res because the action was quasi in rem and the property was located in territory not under the control of the "puppet Republic" is premised on the wrong assumption that the action for the resolution of a contract of sale of real property is quasi in rem. The Supreme Court clarified that such an action is in personam, not quasi in rem. An action in personam has for its object a judgment against the person, based on jurisdiction of the person, even if it involves rights to specific property. The definition of an action in personam was quoted with approval from Grey Alba vs. Dela Cruz, which states that if the technical object of the suit is to establish a claim against a particular person, the action is in personam. The Court further distinguished this from an action in rem or quasi in rem, where the object is to bar all who might make an objection against the right sought to be established, or to subject an individual's interest in property to an obligation or lien. Therefore, the location of the property and the territorial control during the occupation did not divest the court of jurisdiction over the parties in an in personam action. On the issue of due process: The appellants' contention that they were deprived of their day in court is untenable. The records show that the appellants, through their attorney, submitted themselves to the jurisdiction of the Court of First Instance of Iloilo. Their attorney was granted permission to withdraw his appearance due to difficulty in communicating with his clients, who had gone to Arevalo. The hearing was postponed to give the appellants an opportunity to be heard. However, they failed to appear at the rescheduled hearing, and judgment was rendered. Subsequently, their motion for reconsideration and appeal were denied. The Supreme Court held that the absence from the trial was due to their own fault, and therefore, they were not deprived of their day in court. The court's actions were consistent with due process, providing them with the opportunity to be heard, which they failed to avail themselves of.
Main Doctrine
An action to resolve a contract of sale of real property is an action in personam, not quasi in rem. A party submits to the jurisdiction of the court by filing an answer, and the absence from trial due to their own fault does not constitute a deprivation of their day in court.