Case Digest (G.R. No. 138500) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case at hand involves petitioner Andy Quelnan and respondent VHF Philippines, Inc., with the decision rendered by the Supreme Court on September 16, 2005. The dispute arose from an ejectment suit filed by VHF Philippines against Quelnan concerning a condominium unit located at Legaspi Towers 300, Roxas Boulevard, Manila, which VHF claimed had been leased to Quelnan. The Metropolitan Trial Court (MeTC) of Manila held that Quelnan was served summons through his wife on August 25, 1992. On November 23, 1992, the MeTC ruled in favor of VHF, ordering Quelnan to vacate the unit and pay arrears totaling P1,077,497.77, among other sums. A copy of the decision was sent to Quelnan via registered mail, but it was returned unclaimed despite three notices from the postmaster in November and December 1992. With no appeal filed within the reglementary period, the MeTC decision became final.
On May 18, 1993, a writ of execution was served to Quelnan's wife, leading Quelnan to file a Pe
Case Digest (G.R. No. 138500) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Lower Court Proceedings
- In an ejectment suit (Civil Case No. 139649-CV) filed by respondent VHF Philippines, Inc. against petitioner Andy Quelnan concerning a condominium unit at Legaspi Towers 300, Roxas Boulevard, Manila, the Metropolitan Trial Court (MeTC) determined that:
- Petitioner was served by substituted service through his wife on August 25, 1992, upon delivery of the summons accompanied by a copy of the complaint.
- Petitioner failed to file his answer within the reglementary period, leading to a default judgment.
- On November 23, 1992, the MeTC rendered judgment in favor of respondent, ordering petitioner to:
- Vacate the condominium unit and restore possession to VHF Philippines.
- Pay specified sums covering rental arrears, monthly rental for both the condominium and parking lot with legal interest, and attorney’s fees with costs.
- Service of the MeTC Decision and Its Effects
- A copy of the MeTC decision was sent to petitioner through registered mail but was returned unclaimed after three successive notices issued by the postmaster on November 25, 1992, December 7, 1992, and December 11, 1992.
- As no appeal was taken, the decision became final and executory, with the presumption that service was complete pursuant to Rule 13, Section 10 of the 1997 Rules of Civil Procedure.
- Execution Proceedings and the Petition for Relief
- On May 18, 1993, a writ of execution, notice of levy, and notice to vacate were served on petitioner’s wife, who acknowledged receipt.
- Petitioner filed a Petition for Relief from Judgment With Prayer for Preliminary Injunction and/or Temporary Restraining Order on May 24, 1993, with the Regional Trial Court (RTC) at Manila, asserting:
- He was never personally served and was unaware of the ejectment suit until the notice of levy on May 18, 1993.
- His inability to participate in the original proceedings was due to his wife’s act of tearing the summons and complaint during a marital squabble.
- On June 3, 1996, the RTC granted the petition, setting aside the MeTC decision based on alleged excusable neglect and the deprivation of a hearing.
- Appellate Review and Subsequent Rulings
- Respondent sought reconsideration of the RTC decision, but its motion was denied on July 5, 1996.
- The case was elevated to the Court of Appeals (CA) where, in its decision dated September 17, 1997, the CA:
- Reversed and set aside the RTC decision because the petition for relief was filed beyond the required 60-day period, as mandated by Section 3, Rule 38 of the Rules of Civil Procedure.
- Reinstated the original MeTC decision rendered on November 23, 1992.
- Petitioner’s subsequent motion for reconsideration before the CA was denied in its resolution on April 27, 1999.
- Grounds Raised by the Petitioner in the Present Petition
- The petitioner contended that:
- The respondent, in its petition for certiorari, did not contest the RTC orders dated October 26, 1995, and January 26, 1996.
- The MeTC never properly acquired jurisdiction over him since the service of summons was effected through his wife, who allegedly tampered with the process.
- The findings of fact by the MeTC were unsupported by the evidence on record.
- The principal issues thus centered on:
- Establishing the moment when petitioner was deemed to have knowledge of the MeTC decision if he failed to claim the registered mail.
- Determining whether the presumption of completeness in service by registered mail applies to the computation of the 60-day period for filing a petition for relief from judgment.
Issues:
- When is a party considered to have acquired knowledge of an adverse decision if he fails to claim the copy of the decision sent through registered mail?
- Specifically, the issue is whether the 60-day period for filing a petition for relief from judgment should commence on the actual receipt of the decision or on the date when the service is presumed complete under the rules.
- Does the presumption of completeness of service by registered mail under Rule 13, Section 10 of the 1997 Rules of Civil Procedure apply in determining the 60-day period for filing a petition for relief from judgment under Rule 38, Section 3?
- This includes evaluating if the presumed effective service date (November 30, 1992) should trigger the running of the 60-day period, regardless of the petitioner’s actual knowledge.
- Whether the alleged grounds for relief—namely the purported excusable neglect resulting from the actions of petitioner’s wife and the assertion of lack of jurisdiction—are sufficient to overcome the strict application of the 60-day period.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)