Case Summary (G.R. No. 186610)
Factual Background
The case revolves around the compulsory retirement of petitioner Police Senior Superintendent Dimapinto Macawadib from the Philippine National Police (PNP) due to his alleged attainment of the mandatory retirement age of 56 years. General Order No. 1168, issued on July 30, 2001, listed officers due for retirement, including Macawadib, who was recorded as born on January 11, 1946. However, the petitioner later applied for late registration of his birth, asserting he was born on January 11, 1956, which was subsequently approved.
Procedural History
Following the approval of his late birth registration, Macawadib filed a Petition for Correction of Entry regarding his birth date before the RTC in Marawi City, which decided in favor of the petitioner on December 4, 2001. This decision ordered the correction of his birth date across relevant public records. The RTC's decision became final and executory on March 13, 2002. Subsequently, the PNP’s Directorate for Personnel and Records Management filed a Petition for Annulment of Judgment with the CA, claiming a lack of jurisdiction as the PNP was an indispensable party.
Court of Appeals Decision
The CA ruled on December 17, 2008, nullifying the RTC’s decision based on the assertion that the PNP was indeed an indispensable party which had not been impleaded. The CA granted the annulment, preventing Macawadib from continuing his service beyond the mandatory retirement age. A Motion for Reconsideration from the petitioner was denied on February 25, 2009.
Legal Issues Raised
Macawadib contended that the PNP was not an indispensable party and argued that the decision of the RTC had attained finality. He also claimed that the PNP should be estopped from questioning the RTC's decision due to prior action taken by the agencies involved.
Ruling on the Indispensable Party Issue
The Court ruled that the PNP, along with the National Police Commission (NAPOLCOM) and the Civil Service Commission (CSC), were indispensable parties. The integrity of public records necessitates their involvement, as their absence prevented a final determination of the case, rendering the RTC's decision void. The concept of indispensable parties is grounded in the principle that a final adjudication cannot be made in their absence without affecting their interests.
Estoppel Argument
The argument of estoppel was rejected by the Court, affirming that the government is not barred from challenging a judgment based on the omission or mistake of its officials. The State cannot be penalized due to procedural oversights made by its representatives.
Judgment Validity
It was emphasized that a void judgment cannot attain finality and holds no legal weight. The Court expressed skepticism towards the credibility of Macawadib's claim regarding his birth date, highlighti
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Case Overview
- The case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- Petitioner: Dimapinto Macawadib, a Police Senior Superintendent.
- Respondent: The Philippine National Police (PNP) Directorate for Personnel and Records Management.
- The petition seeks to nullify the Decision and Resolution of the Court of Appeals (CA) dated December 17, 2008, and February 25, 2009, which invalidated the Regional Trial Court (RTC) decision on his birth date correction.
Factual Background
- Petitioner was scheduled for compulsory retirement on January 11, 2002, due to reaching the age of 56, as indicated by his PNP records stating his birth date as January 11, 1946.
- On September 3, 2001, he filed for late registration of his birth, claiming he was born on January 11, 1956, which was subsequently approved.
- On October 15, 2001, he petitioned the RTC of Marawi City to correct his birth date in public service records.
RTC Decision
- On December 4, 2001, the RTC ruled in favor of Macawadib, ordering the necessary corrections to his birth date in various government records.
- The decision became final and executory on March 13, 2002, as indicated by an Entry of Final Judgment.
Court of Appeals Proceedings
- On January 8, 2008, the PNP filed a Petition for Annulment of Judgment, arguing the RTC lacked jurisdict