G.R. No. 150722 ; August 17, 2007
SPOUSES EUGENIO & VICENTA REYES, Petitioners, vs. COURT OF APPEALS, THE HON. OSCAR P. BARRIENTOS, as Judge, RTC, Malolos, Bulacan, Br. 82, and RAMIL, JESUS, MELCHOR, JOSEPH and ERWIN, all surnamed VOLUNTAD, Respondents.

FACTS

Private respondents, the Voluntads, filed a Petition for Redemption (Civil Case No. 142-M-93) concerning a foreclosed property. A notice of lis pendens was annotated on the title. While the case was pending, the bank-assignee sold the property to the Dizon spouses, who subsequently sold it to petitioners, the Reyes spouses. The Regional Trial Court (RTC) decided the case on December 8, 1995, in favor of the Voluntads, ordering the Dizon spouses to allow redemption. The Reyes spouses, as subsequent transferees, were not originally impleaded as party-defendants. The Voluntads later sought execution against the Reyes spouses. In a prior Supreme Court case ( G.R. No. 132294 ), the Court ruled on August 26, 1999, that the final judgment was enforceable against the Reyes spouses as transferees pendente lite. The Reyes spouses received a copy of the 1995 RTC decision on May 30, 1997, when the Court of Appeals directed them to comment on a related petition and attached the decision. They filed a Petition for Relief from Judgment on June 21, 2000, contending they were never given their day in court. The RTC dismissed this petition as filed out of time and for lack of legal personality, which the Court of Appeals affirmed.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the Petition for Relief from Judgment for being filed beyond the reglementary periods.

RULING

No. The Supreme Court denied the petition, upholding the dismissal. The reglementary periods for filing a petition for relief from judgment under Rule 38 of the Rules of Court are mandatory and jurisdictional. The petition must be filed within sixty (60) days from the petitioner’s knowledge of the judgment and not more than six (6) months from its entry. The Court ruled that the 60-day period for the Reyes spouses commenced on May 30, 1997, when they received a copy of the December 8, 1995 RTC decision via the CA order. Their subjective belief that the judgment was not binding on them as non-parties is irrelevant. As transferees pendente lite, they are bound by the proceedings and the judgment. The six-month period from the entry of the 1995 judgment had also long expired by the time they filed in 2000. Therefore, filing the petition in June 2000 was indisputably beyond both periods. The Court emphasized that reglementary periods are applied objectively to ensure orderly judicial administration. The CA correctly found no grave abuse of discretion in the RTC’s orders.