Case Summary (G.R. No. 138500)
Factual Background
VHF Philippines, Inc. filed an ejectment suit (Civil Case No. 139649-CV) against Andy Quelnan, asserting that he was in possession of a leased condominium unit. The Metropolitan Trial Court (MeTC) of Manila found that the summons and complaint were served on Quelnan through his wife on August 25, 1992, but Quelnan did not file an answer within the reglementary period. The MeTC ruled in favor of VHF Philippines on November 23, 1992, ordering Quelnan to vacate the property and pay overdue rent and attorney's fees. The decision was sent via registered mail but was returned unclaimed after the petitioner failed to respond to multiple notices.
Procedural History
Following the issuance of a writ of execution on May 18, 1993, Quelnan filed a Petition for Relief from Judgment with the Regional Trial Court (RTC) of Manila on May 24, 1993, claiming he was unaware of the MeTC decision because he had not received the summons. The RTC granted his petition on June 3, 1996, stating that his wife's actions constituted excusable negligence, which hindered him from protecting his rights. However, the Court of Appeals reversed this decision on September 17, 1997, ruling that the petition was filed beyond the 60-day period stipulated in the Rules of Court. Quelnan's motion for reconsideration was subsequently denied on April 27, 1999.
Legal Issues
The primary issues at hand included:
- When a party is deemed to have knowledge of an adverse decision sent via registered mail that they failed to claim.
- The applicability of Rule 13, Section 10 of the 1997 Rules of Civil Procedure regarding the completeness of service of registered mail, in correlation to the 60-day period for filing a petition for relief from judgment as per Rule 38, Section 3.
Knowledge of Judgment and Filing Timelines
Quelnan argued that the 60-day period for filing a petition must be calculated from when he allegedly learned of the adverse judgment. However, the Court ruled that knowledge of the MeTC decision occurred on November 30, 1992, when the service was deemed complete, following the protocol for registered mail service under the law.
Findings on Compliance with Filing Rules
The Court found that Quelnan's petition for relief was filed 175 days after he had deemed knowledge of the decision, which exceeded the allowed 60-day period. The ruling from the RTC that the 60-day period should start upon the party's actual knowledge of the judgment was rejected, as it was contrary to the established jurisprudence regarding the completeness of service presumptions.
Presumption of Completeness of Service
The ruling emphasized that service by registered mail is presumed complete five days after the first notice from the postmaster if not claimed. The absence of a valid justification for Quelnan’s failure to retrieve his mail indicated a lack of excusable neglect and, hence, provided no grounds for the reopening of the case.
Rulings on Jurisdiction and Finality of Judgment
The Court confirmed
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Case Citation
- G.R. No. 138500, September 16, 2005, 507 Phil. 75 (Third Division)
Background of the Case
- The case originated from an ejectment suit (Civil Case No. 139649-CV) filed by VHF Philippines, Inc. against Andy Quelnan concerning a condominium unit at Legaspi Towers 300, Roxas Boulevard, Manila.
- VHF Philippines claimed that Quelnan had leased the unit.
- The Metropolitan Trial Court (MeTC) of Manila ruled in favor of VHF, ordering Quelnan to vacate the premises and pay various amounts, including back rentals and attorney’s fees.
Initial Proceedings
- Summons was served on Quelnan through his wife on August 25, 1992, via substituted service.
- Quelnan failed to file an answer within the reglementary period, leading to the MeTC's decision on November 23, 1992.
- The MeTC decision was sent to Quelnan by registered mail but was returned unclaimed after three notices (November 25, December 7, December 11).
Actions Taken by Quelnan
- On May 18, 1993, Quelnan became aware of the judgment when a notice of levy was served.
- He filed a Petition for Relief from Judgment with the Regional Trial Court (RTC) on May 24, 1993, claiming he was unaware of the proceedings and the judgment against him.
RTC Decision
- The RTC ruled in favor of Quelnan on June 3, 1996, stating he was deprived of a hearing due to the excusable negligence of his wife, who had destroyed