GR 148206; (August, 2007) (Digest)
G.R. No. 148206 ; August 24, 2007
SPOUSES EULOGIO MORALES and ROSALIA ARZADON, Petitioners, vs. SUBIC SHIPYARD & ENGINEERING, INC., Respondent.
FACTS
In 1979, the Republic of the Philippines, acting on a presidential directive, filed a complaint for eminent domain to acquire lands in Zambales for a ship repair facility to be operated by its subsidiary, Philippine Shipyard & Engineering Corporation (PHILSECO). Petitioners Spouses Morales, among other landowners, filed a motion to dismiss, contesting the public use and the Republic’s standing. The trial court denied the motion, authorized immediate possession under P.D. No. 1533, and the Republic deposited provisional compensation. The parties later stipulated that the sole remaining issue was the determination of just compensation. In 1993, after PHILSECO had been privatized and renamed Subic Shipyard & Engineering, Inc. (SSEI), the Morales spouses filed a new motion to dismiss. The trial court granted it in 1995, ruling the expropriation could no longer proceed for a privatized, profit-oriented entity. This dismissal became final.
ISSUE
Whether the Court of Appeals erred in annulling the trial court’s 1995 Resolution dismissing the expropriation complaint on the ground of lack of jurisdiction.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the trial court’s final dismissal. The Court held that a petition for annulment of judgment under Rule 47 is an extraordinary remedy confined strictly to the grounds of extrinsic fraud or lack of jurisdiction. Lack of jurisdiction pertains to either jurisdiction over the person or the subject matter. The trial court unquestionably had jurisdiction over the eminent domain case from its inception. Jurisdiction, once acquired, is retained until the case is fully disposed. Consequently, when the trial court issued the challenged Resolution in 1995, it acted within its jurisdiction. The Court of Appeals therefore erred in annulling a judgment based on a perceived lack of jurisdiction. The Supreme Court emphasized the policy of finality of judgments, stating that litigation must end, and a winning party should not be deprived of a final verdict. The 28-year controversy was thus terminated.