GR 153762; (August, 2005) (Digest)
G.R. No. 153762. August 12, 2005
SUSAN HONORIDEZ, JOSEFINA H. LOPEZ and CONSTANTINA H. SANCHEZ, Petitioners, vs. MAKILITO B. MAHINAY, JOCELYN “JOY” B. SORENSEN and husband name unknown, ARTHUR CABIGON, and FELIMON SUAREZ, Respondents.
FACTS
Petitioners filed a complaint to declare a mortgage deed with respondent Jocelyn Sorensen null due to an allegedly unconscionable interest rate and to prevent foreclosure. They later amended the complaint, alleging an earlier transaction with respondent Felimon Suarez was an equitable mortgage, not a sale. During proceedings, respondent Atty. Makilito Mahinay successfully intervened, citing a final and executory decision in a prior specific performance case (Civil Case No. CEB-16335). That prior case, affirmed by the Court of Appeals, ruled the Suarez transaction was a sale, not a mortgage, and entitled Mahinay to redeem the property from Suarez.
Petitioners then filed three motions: to defer a motion for judgment on the pleadings, for consolidation with the prior case, and for leave to file a third-party complaint against Suarez. They argued a “supervening event”—that they had redeemed the property from Suarez before the prior case’s decision became final—rendered that decision moot and unenforceable. The Regional Trial Court denied all motions, prompting this petition.
ISSUE
Whether the Regional Trial Court erred in denying petitioners’ motions for consolidation and for leave to file a third-party complaint, which were based on the alleged supervening event of redemption.
RULING
The Supreme Court denied the petition, upholding the trial court’s order. The core legal principle applied is the immutability of final judgments. The decision in Civil Case No. CEB-16335, which conclusively ruled the transaction with Suarez was a sale and granted Mahinay redemption rights, had long become final and executory. A final judgment can no longer be altered, even for perceived errors of fact or law, as public policy demands an end to litigation to ensure effective justice.
Petitioners’ claim of a supervening redemption was an impermissible collateral attack on that final judgment. If such redemption indeed occurred during the pendency of the prior case, the proper recourse was to raise it in that very proceeding to allow evidentiary presentation. By seeking to relitigate the nature of the transaction and its consequences through consolidation or a third-party complaint in the new case, petitioners essentially sought to reopen and nullify issues already settled with finality. The Court emphasized that the doctrine of finality of judgment is fundamental and cannot be subverted by attempts to re-litigate matters under a different guise.