GR 144294; (March, 2003) (Digest)
G.R. No. 144294 ; March 11, 2003
SOLEDAD CHANLIONGCO RAMOS, et al., petitioners, vs. TERESITA D. RAMOS, et al., respondents.
FACTS
Respondents, as buyers of a parcel of land co-owned by the late Paulino Chanliongco Jr. and his siblings, filed a Complaint for interpleader before the Regional Trial Court (RTC) to resolve conflicting ownership claims. The RTC upheld the sale only with respect to the share of co-owner Narcisa Chanliongco. On appeal, the Court of Appeals (CA) modified the ruling, declaring the entire sale valid, finding that Narcisa’s daughter, Adoracion Mendoza, acted as a valid sub-agent. This CA Decision became final and executory on August 8, 1996.
Years later, on April 10, 1999, petitioners, who are the children and heirs of Paulino Chanliongco Jr., filed a Motion to Set Aside the final CA Decision. They argued that the judgment was void for lack of due process, contending they were never impleaded as parties nor served with summons and the Complaint in the RTC proceedings. The CA denied their Motion, citing its finality and the petitioners’ lack of legal standing.
ISSUE
Whether the Court of Appeals erred in denying the Motion to Set Aside its final Decision, despite petitioners’ claim of lack of jurisdiction over their persons and denial of due process.
RULING
The Petition is unmeritorious. The CA correctly upheld the immutability of its final judgment. The doctrine of finality of judgment is fundamental; a decision that has attained finality becomes immutable and unalterable. The recognized exceptions are corrections of clerical errors, nunc pro tunc entries, and void judgments. Petitioners’ claim of a void judgment due to lack of jurisdiction and due process fails.
The action filed was an interpleader to determine ownership of real property, which is a real action quasi in rem. The defendants properly impleaded were the estates of the deceased registered co-owners, including the estate of petitioners’ father, Paulino Chanliongco Jr., which was duly represented by its administrator and served with summons. Under the then-governing 1964 Rules of Court, an executor or administrator could sue or be sued alone without joining the beneficiaries or heirs. Thus, there was no requirement to implead the petitioners individually. Jurisdiction over the estate was acquired through service upon its legal representative. Consequently, the final CA Decision is not void, and the denial of the Motion to Set Aside was proper, as petitioners’ interests were represented and protected through the estate’s participation in the litigation.