G.R. No. 157810 ; February 15, 2012
ROLANDO SOFIO and RUFIO SOFIO, Petitioners, vs. ALBERTO I. VALENZUELA, GLORIA I. VALENZUELA, REMEDIOS I. VALENZUELA, and CESAR I. VALENZUELA, Respondents.

FACTS

Respondents, co-owners of agricultural land, alleged that petitioners Rolando and Rufio Sofio illegally occupied portions of their property. Rolando initially farmed an abandoned area with permission from the respondents’ mother, conditioned on its return when needed. The petitioners later expanded their cultivation. In 1988, Emancipation Patents (EPs) were issued to the petitioners. The respondents filed a complaint before the DARAB seeking cancellation of the EPs and recovery of possession, arguing no valid tenancy relationship existed. The Provincial Agrarian Reform Adjudicator (PARAD) ruled for the respondents, cancelling the EPs. The DARAB reversed, finding a tenancy relationship. The Court of Appeals (CA) then reinstated the PARAD decision, ruling no tenancy was proven. The CA decision became final and executory, and an entry of judgment was issued.
The petitioners, through new counsel, filed a motion to recall the entry of judgment with the CA. They argued their previous counsel was negligent for failing to file a motion for reconsideration or a petition for review with the Supreme Court, thereby depriving them of due process. The CA denied the motion. The petitioners elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals gravely abused its discretion in denying the motion to recall the entry of judgment based on the alleged gross negligence of petitioners’ former counsel.

RULING

The Supreme Court denied the petition and affirmed the CA resolution. The Court emphasized the doctrine of finality and immutability of judgments. A decision that has attained finality becomes immutable and unalterable. Exceptions to this rule are applied only under extraordinary circumstances, such as when the negligence of counsel is so gross, reckless, and inexcusable that it effectively deprives the client of due process. In this case, the petitioners failed to substantiate such a deprivation. Their former counsel’s failure to pursue further remedies was a tactical error or simple negligence, not the gross negligence required to nullify the final judgment. The Court held that clients are generally bound by the actions, even mistakes, of their counsel in the conduct of a case. The other substantive issues raised by the petitioners regarding tenancy had already been conclusively settled by the final CA decision. Reopening these matters would violate the principle of finality. Thus, the CA committed no grave abuse of discretion in upholding the entry of judgment.