Case Summary (G.R. No. 231826)
Antecedents
Petron Corporation entered into a Lease Agreement with the Philippine National Oil Company (PNOC) on November 26, 1993, pertaining to landholdings in Brgy. Alangan, Limay, Bataan, specifically covering a portion identified as Cadastral Lot No. 257-A under Transfer Certificate of Title No. T-167116. The petitioners, Palma brothers, had been occupying the area since the early 1980s under the toleration of PNOC and its predecessors. Petron continued this tolerance until 2007 when it announced the planned development of the Petron Skills Training Center in the area, urging the petitioners to relocate. Following the petitioners’ refusal to vacate after a Final Notice to Vacate issued on August 8, 2008, Petron initiated an unlawful detainer complaint in the Municipal Trial Court (MTC) of Limay, Bataan.
MTC Decision and Appeal
On July 1, 2009, the MTC ruled in favor of Petron, ordering the petitioners to vacate the premises. Petitioners appealed the MTC's decision to the Regional Trial Court (RTC), but on February 10, 2010, the RTC dismissed the appeal due to the petitioners' failure to comply with its directive to file an appellants' memorandum as required by the Rules of Court. Attempts at relief through a subsequent petition were denied, with the Court of Appeals (CA) dismissing the petition for certiorari in 2012, thereby upholding the RTC's decision.
Subsequent Legal Actions
Despite the earlier definitive rulings, petitioners continued their legal pursuits. They filed a Petition for Annulment of Judgment before the CA in January 2016, challenging not only the RTC's decision but also the Writs of Execution and Demolition issued by the MTC. Petitioners asserted that the RTC lacked jurisdiction and that the MTC's decision was void due to circumstantial deficiencies in jurisdictional requirements.
Court of Appeals Decision
On January 16, 2017, the CA denied the petitioners’ request for annulment, affirming the orders of the RTC and the MTC. The CA established that to qualify for an annulment under Rule 47 of the Rules of Court, petitioners must demonstrate that ordinary remedies were unavailable through no fault of their own; they did not satisfy this condition. Furthermore, the CA found the petitioners liable for forum shopping.
Legal Issues
The primary question was whether the CA erred in denying the petitioners’ petition for annulment of judgment. The ruling concluded that the MTC correctly had jurisdiction to adjudicate the unlawful detainer case, as the allegations in Petron's complaint satisfied the criteria stipulated
...continue readingCase Syllabus (G.R. No. 231826)
Background of the Case
- The case originated from a Petition for Review on Certiorari filed by Adolfo C. Palma and Rafael Palma against Petron Corporation.
- The Petition assailed the Decision dated January 16, 2017, of the Court of Appeals (CA) in CA-G.R. SP No. 143888, which denied their Petition for Annulment of Judgment.
- The CA also denied the petitioners' Motion for Reconsideration in a subsequent Resolution dated April 20, 2017.
Antecedents
- On November 26, 1993, Petron Corporation entered a 25-year Lease Agreement with the Philippine National Oil Company (PNOC) over various landholdings in Brgy. Alangan, Limay, Bataan, including Cadastral Lot No. 257.
- Petitioners had been occupying a portion of Lot No. 257-A by mere tolerance since the early 1980s, with no immediate need for the land by PNOC.
- In 2007, Petron notified petitioners that the land would be used to construct the Petron Skills Training Center and requested them to vacate the premises.
- A Final Notice to Vacate was issued on August 8, 2008, but the petitioners failed to leave, prompting Petron to file a Complaint for Unlawful Detainer before the Municipal Trial Court (MTC).
Initial Court Decisions
- On July 1, 2009, the MTC ruled in favor of Petron, ordering the petitioners to vacate and pay attorney's fees.
- Petitioners appealed to the Regional Trial Court (RTC) but their appeal was dismissed due to failure to comply with procedural requirements.
- Subsequent motions for relief and recon