A judicial controversy ends once the judgment becomes final. This is illustrated in this case of a real estate corporation (SHC).
SHC filed a complaint before the Regional Trial Court (RTC) for annulment of sale, cancellation of titles, re-conveyance and damages involving one of its real properties which was allegedly sold to a management company (IAC) by its assistant vice president (AVP) without its knowledge and consent and without the requisite board resolution.
Since IAC had already sold the land to a development bank (DBR) which in turn had sold it to a financing company (IFRC), while the latter had subsequently sold the same to a realty developer HRDC, the complaint of IAC included all these parties aside from the Register of Deeds as respondents.
For its part, respondent HRDC, the present owner and last transferee filed a motion to dismiss on the ground that the complaint stated no cause of action. HRDC alleged that the TCTs attached to the complaint clearly showed that the AVP was authorized to sell and that the Deed of Absolute Sale he signed was duly notarized wherein the receipt of the total price of the land was duly acknowledged. HRDC further alleged that based on the complaint, SHC might not even be a real party in interest to the subsequent successive transfers of the properties after IAC.
SHC opposed this motion by merely insisting that it had a cause of action without however refuting HRDC’s material assertions. On the other hand, only IFRC filed an answer. The other respondents failed to file their respective responsive pleadings.
On July 3, 2002, the RTC dismissed the complaint against HRDC and all the other respondents for failure to state a cause of action. It also ruled the action for re-conveyance was not proper since the properties had already passed on to innocent purchasers in good faith and for value.
The said ruling was affirmed on appeal by the Court of Appeals (CA) and subsequently by the Supreme Court (SC) in a petition for review on certiorari which find no reversible error in said decision. It became final after the SHC motion for reconsideration was denied by the SC and an entry of judgment was already issued.
But SHC did not stop there. It filed another petition in the CA for annulment of the same July 3, 2002 order of the RTC on the ground of lack of jurisdiction, arguing that the latter overstepped its boundaries when it dismissed the complaint not only against HRDC but also against all the other respondents when it was only HRDC that moved for the dismissal. SHC contended that it was denied due process as against the said other respondents. Was SHC correct?
No. SHC’s complaint went to great lengths to trace who the first of its property was (IAC) down to the current owner thereof, HRDC. As title to the contested property is now vested in HRDC, there was really no need for SHC to implead all the other respondents for the successful prosecution of its action for annulment of sale against HRDC. All the other respondents were not even real parties in interest to begin with. The only real parties in interest in this controversy were SHC and HRDC for they were the only ones that stood to be benefitted or injured, as the case may be, by the judgment in the suit.
Furthermore, since SHC had already appealed the case and lost, it could no longer avail of a petition for annulment of judgment. A petition for annulment of judgment is an extraordinary remedy allowed only in exceptional cases and cannot be used by a losing party to make a mockery of a duly promulgated decision long final and executory. It cannot be invoked where the party had already availed of any other appropriate remedies (like appeal or petitions for new trial or for relief from judgment) and lost, or where it has failed to avail itself of those remedies through its own fault or negligence.
It is essential to an effective and efficient administration of justice that, once a judgment becomes final, the winning party should not be deprived of the fruits of the verdict. Courts must therefore guard against any scheme calculated to bring about that undesirable result. Thus it is fit to put an end to this controversy (Sigma Homebuilding Corp. vs. Inter-Alia Management Corp. et.al. G.R. 177898, August 13, 2008).
This is an ideal principle. Unfortunately it is not always followed. In fact I know of one case where a petition was already denied with finality by the SC but it was still revived on a second motion for reconsideration after more than two years. Justice may still be elusive even up to the court of last resort.
Note: Books containing compilation of my articles on Labor Law and Criminal Law (Vols. I and II) are now available. Call tel. 7249445.
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E-mail at: jcson@pldtdsl.net