Republic v. De Castro

G.R. No. 189724 (February 7, 2011)

SC upheld trial court's ruling, citing lack of notice to De Castros, affirming jurisdiction post-death.

Facts:

On July 13, 1955, the Director of the Bureau of Lands issued Free Patent No. V-16555 under Free Patent Application No. V-33580 for Lot No. 6742, Pls-296, covering an area of 5.376 hectares located in Naujan, Oriental Mindoro, in the name of Marcelino Manipon. This patent was subsequently used to obtain Original Certificate of Title (OCT) No. P-2124, which was issued by the Register of Deeds of Oriental Mindoro on March 5, 1957. Manipon later sold the lot to Spouses Florencio and Romelia de Castro (respondents), who were then issued Transfer Certificate of Title (TCT) No. T-33730 after the cancellation of OCT No. P-2124.

In 1998, an investigation by the Lands Management Bureau revealed that the lot was not alienable and disposable land of the public domain, as it was within the Paitan Mangyan Reservation, established by Proclamation No. 809 on June 4, 1935. The investigation indicated that Manipon had only begun occupying the lot in 1944 and that neither he nor the respondents had established any right to possess or own the lot. Consequently, the Republic of the Philippines, represented by the Office of the Solicitor General, filed a complaint for "Cancellation of TCT No. T-33730 and Reversion" against Manipon (who had died ten years prior) and the respondents, as well as the Register of Deeds of Calapan, Oriental Mindoro, in Civil Case No. R-4694.

The respondents failed to file an answer to the complaint despite being served summons and were declared in default. Their motion to lift the order of default was denied. The trial court subsequently rendered a decision on October 9, 2002, nullifying Manipon's Free Patent and the respondents' TCT, ordering the reversion of the lot to the State, and directing the respondents to vacate the lot and surrender their title for cancellation. The respondents did not file a motion for reconsideration or appeal, making the decision final and executory.

On April 29, 2004, the trial court issued a writ of execution, which was served on the respondents on March 29, 2005, and implemented on July 20, 2006. On March 15, 2007, the respondents filed a petition for annulment of judgment before the Court of Appeals, arguing that the trial court lacked jurisdiction over Manipon since he was deceased at the time of the complaint and that they had not received a copy of the trial court's decision, rendering the execution void.

Legal Issues:

  1. Did the trial court have jurisdiction over the case despite Manipon's death at the time the complaint was filed?
  2. Did the respondents have a valid basis for seeking annulment of the trial court's decision due to lack of service of the decision?
  3. Were the respondents barred from seeking annulment due to their failure to avail of other remedies?

Arguments:

  • Petitioner (Republic of the Philippines): The petitioner argued that the trial court's decision was valid and final since the respondents failed to file any motion for reconsideration or appeal. The petitioner contended that the respondents had ample opportunity to question the decision but did not do so, and thus, they should not be allowed to benefit from their inaction.

  • Respondents (Spouses de Castro): The respondents maintained that they did not receive a copy of the trial court's decision, which meant that the decision had not become final and executory. They argued that the trial court lacked jurisdiction over Manipon since he was deceased when the complaint was filed, and therefore, their title, which derived from Manipon, should remain valid.

Court's Decision and Legal Reasoning:

The Court of Appeals initially denied the respondents' petition for annulment of judgment but found that they had not been served with a copy of the trial court's decision, which meant that the decision had not yet become final. Consequently, the appellate court nullified the trial court's order for execution and directed the trial court to serve a copy of its decision to the respondents.

However, upon review, the Supreme Court reversed the appellate court's decision. The Court emphasized that the remedy of annulment of judgment under Rule 47 of the Rules of Civil Procedure is only available when a party has failed to avail of ordinary remedies through no fault of their own. The Court noted that the respondents had ample opportunity to question the trial court's decision after they were served with the writ of execution but failed to do so without justification. The Court reiterated that a party cannot resort to annulment as a substitute for their own neglect in pursuing available remedies.

Significant Legal Principles Established:

  1. The remedy of annulment of judgment is an extraordinary remedy that should only be availed of under exceptional circumstances where the party has failed to pursue ordinary remedies without fault on their part.
  2. A party's failure to act on a judgment or decision, despite having knowledge of it and available remedies, bars them from seeking annulment of that judgment.
  3. Jurisdiction over a deceased party is not automatically void; the validity of the proceedings may depend on the circumstances surrounding the case.