Case Summary (G.R. No. 248971)
Relevant Background and Procedural History
On July 6, 1988, the private respondents filed an ejectment case dated April 15, 1988, against the petitioner, claiming she had illegally constructed a house on a 4.5-hectare lot owned by them in Labahan, San Mateo, Rizal, back in 1986. Despite receiving two demand letters, the petitioner did not vacate the premises. The summons and complaint were served on the petitioner through her daughter, Nancy de Guzman, after the Municipal Trial Court (MTC) determined it was appropriate to use substituted service. The petitioner failed to respond within the stipulated time, leading to a judgment by default on August 17, 1988, wherein the MTC ordered her to vacate and awarded attorney's fees to the respondents.
Court Actions and Petitioner’s Defense
Following the MTC's decision, a Writ of Execution was issued on October 18, 1988. The petitioner filed a Motion for Reconsideration, which was denied, prompting her to submit a Petition for Relief from Judgment and others to the Regional Trial Court (RTC) on January 19, 1989. The petitioner contended that she was denied due process due to improper service of summons and challenged the MTC's jurisdiction, citing a two-year delay in filing the complaint after her alleged unlawful entry.
Regional Trial Court Ruling
The RTC ruled on July 10, 1992, in favor of the petitioner, finding the service of summons improper and declaring that the ejectment suit was filed beyond the prescriptive period. The RTC held that valid substituted service of summons requires proof of the impossibility of personal service, which was not established in this case. Moreover, the RTC determined that the actions of the private respondents had prescribed, as the forcible entry case was filed two years after the alleged stealthy occupation occurred.
Appeal to Court of Appeals
The private respondents subsequently appealed this decision. On January 24, 1995, the Court of Appeals dismissed the RTC’s ruling, stating that the petitioner had pursued the wrong remedy by filing a petition for relief, as there was no indication of any grounds such as fraud or mistake warranting such relief. The Court of Appeals ruled that the decision from the MTC had become final and executory due to the petitioner's failure to appeal that judgment timely. It also concluded that the petitioner failed to prove ownership of the property, as her predecessors were categorized as squatters.
Supreme Court's Findings
The Supreme Court found the petition meritorious, e
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Case Overview
- This case involves a petition for review under Rule 45 of the Rules of Court, filed by Nena de Guzman against the Court of Appeals and respondents Ignacio Raneses and Isagani Raneses.
- The petition aims to set aside the decision of the Court of Appeals which affirmed the decision of the Regional Trial Court of San Mateo, Rizal, requiring the petitioner to vacate the disputed premises.
Factual Background
- An ejectment case was initiated on July 6, 1988, by private respondents Isagani and Ignacio Raneses against Nena de Guzman, dated April 15, 1988, and docketed as Civil Case No. 717 in the Municipal Trial Court of San Mateo, Rizal.
- The respondents accused the petitioner of unlawfully constructing a house on their 4.5-hectare property in Labahan, San Mateo, Rizal, by stealth in 1986.
- Despite receiving two demand letters from the respondents, the petitioner refused to vacate the premises.
- Summons and a copy of the complaint were served on the petitioner through her daughter, Nancy de Guzman, on July 27, 1988. The petitioner did not file an answer within the reglementary period, prompting the respondents to move for summary judgment.
Judicial Proceedings
- On August 17, 1988, the Municipal Trial Court, presided by Judge Apolinar T. Antazo, issued a judgment by default directing the petitioner to vacate the disputed lots and pay P2,000.00 as attorney's fees.
- Following the issuance of a Writ of Execution on October 18, 1988, the petitioner’s counsel filed a Motion for Reconsideration, which was denied.
- On January 19, 1989, the petitioner filed a Petition for Relief from Judgment, Injunction, and Damages in the Regional Trial Court, arguing that she was denied due process due to improper service of summons.