GR 131741; (July, 2006) (Digest)
G.R. No. 131741 ; July 31, 2006
SPS. BERNARDO V. ATIENZA and EUFROCINA M. ATIENZA, petitioners, vs. THE COURT OF APPEALS, GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), EX-OFFICIO SHERIFF of MAKATI, The REGISTERS OF DEEDS of MAKATI & MALABON, and Sps. JEAN and MELANIO N. DE OCAMPO, respondents.
FACTS
Petitioners obtained a housing loan from respondent GSIS secured by a real estate mortgage. After alleged defaults, GSIS foreclosed on the properties in 1984 despite petitioners’ claim of having made payments. Petitioners subsequently filed three separate complaints for injunction in different Regional Trial Courts (RTCs) to restrain GSIS from selling the foreclosed properties. All three cases were dismissed on grounds of improper venue, litis pendentia, and res judicata. Petitioners then filed a new complaint for annulment of sale (Civil Case No. 94-2342) before the RTC of Makati. GSIS moved to dismiss this complaint on grounds including forum shopping, citing petitioners’ admission in their certification of non-forum shopping about the three prior injunction cases. The RTC granted the motion to dismiss.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the complaint for annulment of sale.
RULING
The Supreme Court denied the petition. The legal logic is anchored on the finality of judgments and the prohibition against forum shopping. The Court found that the order dismissing Civil Case No. 94-2342 had already attained finality. Petitioners had previously challenged this dismissal order via a petition for certiorari before the Court of Appeals, which was denied for being the wrong remedy, as an ordinary appeal was the proper recourse. This denial was subsequently affirmed by the Supreme Court in a prior resolution (G.R. No. 125268). Consequently, the dismissal order became final and executory. The present petition, which essentially seeks to relitigate the same matter, constitutes an impermissible attempt to reopen a finally adjudicated case. The Court emphasized the fundamental principle that litigation must end, and a final judgment by a competent court must bind the parties to prevent endless suits that harass the prevailing party and obstruct the administration of justice. The alleged extrinsic fraud raised by petitioners was not substantiated to warrant an exception to this rule.