Title
Grande vs. University of the Philippines
Case
G.R. No. 148456
Decision Date
Sep 15, 2006
Petitioners sought annulment of a final CA judgment due to counsel's negligence, but SC dismissed, citing Rule 47's inapplicability and finality of judgment.
annulment of judgment
procedural errors
lack of exceptional circumstances
A

Case Digest (G.R. No. 148456)

Facts:

  • Parties Involved
    • Petitioners:
      • Pio C. Grande, Rufino C. Grande, Aida C. Grande, Florencia Grande-Santos, Teresita Grande-Viola, Josephine Grande Domingo (representing the heirs of Crisanta Grande-Domingo)
      • Estanislao Quibal (representing the heirs of Rosita Grande-Quibal)
    • Respondent:
      • University of the Philippines
  • Nature and Background of the Case
    • The case involves a "Petition for Annulment of Judgment" seeking to nullify:
      • The Court of Appeals (CA) decision dated December 14, 1999, dismissing the petitioners’ appeal.
      • The Resolution dated February 24, 2000, which denied the petitioners’ motion for reconsideration.
    • The dispute arises from an earlier complaint filed by petitioners for recovery of ownership and reconveyance of a subject property.
    • The property in issue had been previously covered by a Torrens title issued as early as 1914, while petitioners initiated legal proceedings only in 1984.
  • Procedural History and Timeline
    • Regional Trial Court (RTC)
      • The RTC of Quezon City dismissed petitioners’ complaint on the ground of lack of cause of action because the property had already been acquired by the respondent as an innocent purchaser for value during the intervening period.
    • Court of Appeals (CA)
      • The CA affirmed the RTC decision by dismissing the appeal in CA-G.R. CV. No. 44411.
      • Petitioners, through their former counsel, received copies of the CA Decision (December 28, 1998) and the Resolution on reconsideration (March 17, 2000).
    • Finality of the CA Judgment
      • The CA decision became final and executory on April 12, 2000.
    • Petition for Annulment
      • Filed on June 29, 2001, over a year after the CA decision became final.
      • Petitioners asserted that their former counsel’s negligence in informing them of the CA rulings justified the annulment.
  • Legal Grounds and Contentions Raised
    • Petitioners’ Argument
      • The petition for annulment was presented as a remedy against the final and executory judgment.
      • Petitioners claimed that counsel’s negligence prevented them from timely reacting to the CA decision.
    • Respondent’s Position
      • Argued that the petition lacked procedural sanction under the Rules of Court.
      • Contended that a petition for annulment is equitable in nature and available only under exceptional circumstances.
    • Collateral Matter
      • A subsequent dispute arose between the former counsel (who had signed a contingent fee agreement) and the new counsel.
      • This issue was noted as moot given the overall dismissal of the petition.
  • Applicable Procedural and Jurisdictional Rules
    • Rule 47 of the 1997 Rules of Civil Procedure
      • Governs the annulment of judgments or final orders of Regional Trial Courts when no other remedy is available.
      • Explicitly does not apply to decisions of the Court of Appeals.
    • Scope of Original Jurisdiction
      • The Constitution and relevant procedural rules limit the Court’s original jurisdiction to petitions such as certiorari, prohibition, mandamus, and others—not petitions for annulment of appellate decisions.
    • Appeal by Certiorari
      • Even if treated as an appeal by certiorari, such petitions must be filed within 15 days from receipt of the judgment, which was not complied with in this case.

Issues:

  • Jurisdiction and Appropriateness of the Petition
    • Whether the petition for annulment of the CA decision is procedurally and legally allowable given that the underlying judgment had already become final and executory.
    • Whether the petition falls within the ambit of cases originally cognizable by the Court considering the limitations set by the Rules of Court and pertinent constitutional provisions.
  • Timeliness and Procedural Defaults
    • Whether the petition, filed more than a year after the CA judgment became final, can be admissible as an appeal or as a special civil action.
    • Whether the alleged failure of petitioners’ former counsel to timely inform them of the CA rulings constitutes a basis for re-opening a final case.
  • Grounds for Annulment and the Alleged Negligence
    • Whether the negligence of the petitioners' former counsel, in not communicating the receipt of the Resolution denying their motion for reconsideration, is sufficient to justify the annulment of the final judgment.
    • Whether such negligence, if any, falls within the threshold of "gross or palpable" negligence that would otherwise entitle relief under the doctrine binding clients to their counsel's representation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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