Title
Aramburo vs. Court of Appeals
Case
G.R. No. 50711
Decision Date
Nov 17, 1980
Petitioners claimed denial of due process after Court of Appeals ruled against them without their brief, but Supreme Court upheld the decision as final and executory.
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Case Digest (G.R. No. 50711)

Facts:

1. Initial Proceedings:

  • On January 14, 1963, petitioners filed an application for registration of Lots Nos. 2361 and 4725 of the Cadastral Survey of Malinao in the Court of First Instance of Albay, docketed as Land Registration Case No. 311.
  • Private respondent Concepcion R. Pena opposed the application, claiming ownership of the lots.
  • On May 23, 1964, Pena filed an action for reivindicacion with damages (Civil Case No. 2850) to recover the two lots and Lot No. 2360, which was in the possession of Jose Atadero.
  • Both cases were jointly tried, and on February 14, 1968, the Court of First Instance of Albay dismissed both cases.

2. Appeal to the Court of Appeals:

  • Pena appealed the dismissal to the Court of Appeals, docketed as CA-G.R. No. 41251-R.
  • Pena filed her appellant’s brief, but petitioners (appellees) did not file a brief.
  • On September 23, 1971, the Court of Appeals issued a resolution considering the case submitted for decision without the appellees’ brief.
  • Over seven years later, on December 28, 1978, the Court of Appeals reversed the lower court’s decision, declaring Pena the absolute owner of the lots and ordering the petitioners to vacate and deliver possession, along with other reliefs.

3. Petitioners’ Claims:

  • Petitioners claimed they were deprived of procedural due process because they were not served a copy of Pena’s appellant’s brief and were unaware of the Court of Appeals’ resolution and decision until May 9, 1979, when the writ of execution was served.
  • They argued that their failure to file a brief was due to non-receipt of the appellant’s brief.

4. Respondents’ Counterarguments:

  • Respondents asserted that petitioners’ counsel was served with the appellant’s brief, as evidenced by registry receipts and return cards.
  • They argued that the petitioners’ failure to appeal or seek reconsideration rendered the decision final and executory.

5. Supreme Court Proceedings:

  • The Supreme Court issued a temporary restraining order on June 15, 1979, halting the execution of the Court of Appeals’ decision.
  • The Court of Appeals’ Division Clerk of Court reported that the appellant’s brief did not have a registry return receipt from petitioners’ counsel, but registry receipts and return cards for the resolution and decision were attached to the rollo.
  • Petitioners’ counsel denied receiving the appellant’s brief, resolution, or decision, claiming the signatures on the return cards were unknown to them.

Issue:

  1. Whether the petitioners were deprived of procedural due process when the Court of Appeals decided the case without their brief as appellees.
  2. Whether the Court of Appeals erred in considering the case submitted for decision without the appellees’ brief.
  3. Whether the decision of the Court of Appeals had become final and executory due to the petitioners’ failure to appeal or seek reconsideration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled that the petitioners were not deprived of procedural due process, as they had ample opportunity to address the procedural defect but failed to act. The decision of the Court of Appeals was final and executory, and the execution of the judgment was upheld.


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