G.R. No. 133547 & G.R. No. 133483 February 10, 2000
HEIRS OF ANTONIO PAEL and ANDREA ALCANTARA and CRISANTO PAEL, petitioners, vs. COURT OF APPEALS, JORGE H. CHIN and RENATO B. MALLARI, respondents. x—————————–x MARIA DESTURA, petitioner, vs. COURT OF APPEALS, JORGE H. CHIN and RENATO B. MALLARI, respondents.

FACTS

The consolidated petitions originated from two related complaints concerning a parcel of land. Pedro Destura first filed a complaint (Civil Case No. Q-93-14522) against Jorge Chin and Renato Mallari for annulment of title, reconveyance, and nullification of a Memorandum of Agreement (MOA) dated March 26, 1992. The trial court dismissed this complaint for lack of cause of action, a decision affirmed by the Court of Appeals, which upheld the MOA’s validity and Chin and Mallari’s titles. This judgment became final and executory. Subsequently, Pedro’s wife, Maria Destura, filed a nearly identical complaint (Civil Case No. Q-93-18569), initially impleading her husband as a defendant to avoid res judicata, but later dropping him.
In the second case, the trial court rendered a default judgment against Chin and Mallari. Surprisingly, the decision nullified the MOA and ordered the cancellation of Chin and Mallari’s titles, but did not award the property to plaintiff Maria Destura. Instead, it directed the Register of Deeds to reinstate the original title (TCT No. 36048) in the names of the Paels, who were not parties to the suit. Maria Destura did not appeal this decision, allowing it to become final as to her. The Pael heirs, who were non-parties but beneficiaries of the trial court’s order, and Maria Destura, who intervened later, separately challenged the Court of Appeals’ subsequent decision which set aside the trial court’s default judgment.

ISSUE

The primary issue is whether the trial court’s decision in Civil Case No. Q-93-18569, which granted relief to non-parties (the Pael heirs) and from which the plaintiff (Maria Destura) did not appeal, is valid and binding.

RULING

The Supreme Court ruled that the trial court’s decision was void for lack of jurisdiction. A court cannot grant relief to persons who are not parties to the action. The Pael heirs were not impleaded, did not intervene, and were strangers to the case. Therefore, the portion of the judgment ordering the reinstatement of title in their favor was a patent nullity. The Court emphasized that a decision is void if it confers rights upon a non-party, as it violates the fundamental principle that jurisdiction over a case is acquired only over the parties therein.
Furthermore, the finality of the judgment against Maria Destura was pivotal. By not appealing the trial court’s decision that denied her any affirmative relief, she acquiesced to its dispositive portion. The judgment became final as to her, precluding her from subsequently claiming any right over the property. Her belated intervention in the Supreme Court could not revive a lost appeal or challenge a final judgment. Consequently, the Court of Appeals correctly annulled the trial court’s void decision and reinstated the titles of Chin and Mallari. The petitions were denied for lack of merit.