Case Digest (G.R. No. 148132)
Facts:
The case involves a dispute between Adolfo C. Palma and Rafael Palma (collectively referred to as "petitioners") and Petron Corporation (respondent). The events that led to this litigation began on November 26, 1993, when Petron Corporation entered into a 25-year Lease Agreement with the Philippine National Oil Company (PNOC) for various properties located in Brgy. Alangan, Limay, Bataan, encompassing a total land area of 2,397,929 square meters which included Cadastral Lot No. 257 covering 92,392 square meters. Since the early 1980s, the petitioners had been occupying a portion of Lot No. 257-A with the tolerance of PNOC and its predecessor. Even after Petron's lease agreement with PNOC, the company allowed the petitioners to continue their possession due to a lack of immediate need for the area.
In 2007, Petron notified the petitioners that the land would be utilized for the construction of the Petron Skills Training Center and urged them to find alternative ho
Case Digest (G.R. No. 148132)
Facts:
Petron Corporation entered into a 25‐year lease with the Philippine National Oil Company (PNOC) in 1993 for the use of refinery properties in Bataan. Among the leased properties was Lot No. 257, which petitioners—having occupied a portion of it since the early 1980s by mere tolerance and acquiescence—were using. In 2007, Petron notified petitioners that the area would be developed into the Petron Skills Training Center and advised them to seek relocation. On August 8, 2008, petitioners received a Final Notice to Vacate, but they refused to leave. Consequently, Petron filed an Unlawful Detainer action before the Municipal Trial Court (MTC) of Limay, which rendered a decision in its favor on July 1, 2009, ordering the petitioners to vacate and awarding attorney’s fees and costs.Petitioners sought to challenge the decision by appealing to the Regional Trial Court (RTC) in Civil Case No. 817-ML; however, their appeal was dismissed on February 10, 2010 for failing to comply with the required filing of their appellant’s memorandum. Their subsequent motions for reconsideration before the RTC were also denied. Petitioners then elevated the matter through petitions for certiorari before the Court of Appeals (CA) and later a petition for review before the Supreme Court, all of which were dismissed on procedural and merit-related grounds.
Notwithstanding these final and executory decisions, petitioners filed a Petition for Annulment of Judgment before the CA on January 22, 2016, alleging that the MTC’s decision was rendered without jurisdiction—arguing that the requisite one-year filing period for an unlawful detainer was not met—and attributing certain errors to their counsel. On January 16, 2017, the CA denied the petition for annulment and affirmed the lower court’s decisions. An ensuing motion for reconsideration was likewise denied on April 20, 2017.
Issues:
- Whether the CA erred in denying petitioners’ petition for annulment of judgment based on alleged lack of jurisdiction of the MTC in the wrongful detainer action.
- Whether petitioners, by failing to avail themselves of the proper and timely remedies (i.e., appeal or motion for reconsideration) and subsequently claiming mistakes attributable to their counsel, may validly raise a petition for annulment under Rule 47.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)