G.R. No. L-18402; November 29, 1962
CANDIDO BUENA, plaintiff-appellant, vs. ELVIRA SAPNAY, SALOME SAPNAY, GERTRUDES SAPNAY, MANUEL BULACAN, PASCUAL SACUEZA, FLORO SACUEZA, FLORENCIA SACUEZA, JUANA SACUEZA, MARCELINA DE SACUEZA, EMILIO SACUEZA, JR., defendants-appellees.

FACTS

Plaintiff Candido Buena obtained a pre-war judgment against the original defendants. The records were destroyed during the war. In 1950, Buena applied for the reconstitution of the judgment in Case No. R-237. At the time of this application, two original judgment debtors were already deceased. Of the remaining living defendants, only Manuel Bulacan was notified of the hearing, and his notice was mailed only three days before the scheduled date, resulting in him receiving it after the hearing had already taken place. The other four living defendants received no notice at all. The court proceeded with the hearing and issued an order reconstituting the records, including the decision, based on a simple copy of the original judgment attached to the application. Buena later filed the present action to revive this reconstituted judgment.

ISSUE

Whether the trial court correctly dismissed Buena’s complaint for revival of judgment based on the reconstituted decision.

RULING

Yes, the trial court correctly dismissed the complaint. The Supreme Court affirmed the dismissal, holding that the reconstituted judgment was null and void. The legal logic rests on the jurisdictional defects in the reconstitution proceedings. Act No. 3110 mandated that notice of the reconstitution hearing be sent to all interested parties by the Clerk of Court. This was not complied with. The notice to Bulacan was defective due to its tardiness, and the other defendants were not notified at all. Consequently, the court in the reconstitution case never acquired jurisdiction over the persons of the defendants. A judgment rendered by a court without jurisdiction is void. A void judgment, as established in jurisprudence, is “a lawless thing” that can be attacked collaterally at any time and need not be respected. Since Buena’s complaint for revival was based on this void reconstituted decision, it had no legal leg to stand on. The Court found it unnecessary to rule on the secondary issue of whether the simple copy used for reconstitution qualified as the “authentic copy” required by law, as the foundational order of reconstitution was already invalid for lack of jurisdiction.