GR 165544; (October, 2009) (Digest)
G.R. No. 165544; October 2, 2009
Romeo Samonte, Petitioner, vs. S.F. Naguiat, Inc., Respondent.
FACTS
Respondent S.F. Naguiat, Inc. filed a collection suit against S.B. Commercial Traders, Inc. and its President, petitioner Romeo Samonte, for unpaid Mobil oil products. The complaint alleged that the corporation was Samonte’s alter ego, making him solidarily liable. Samonte filed an answer but, despite notice, failed to appear at the pre-trial conference. The Regional Trial Court (RTC) proceeded with an ex parte presentation of evidence and rendered a judgment holding Samonte and the corporation jointly and severally liable. Samonte failed to appeal this decision, leading to its finality and the issuance of a writ of execution.
Subsequently, Samonte filed a petition for relief from judgment with the RTC, arguing he could not be held solidarily liable for corporate obligations due to the separate juridical personality doctrine. He did not, however, assert that the judgment was rendered through fraud, accident, mistake, or excusable negligence, nor did he attach the required affidavit of merit. The RTC denied his petition. The Court of Appeals (CA) dismissed his subsequent certiorari petition, affirming the RTC’s denial.
ISSUE
Whether the Court of Appeals erred in affirming the denial of Samonte’s petition for relief from judgment.
RULING
The Supreme Court denied the petition and affirmed the CA. The Court emphasized that a petition for relief from judgment is an extraordinary remedy governed by strict procedural requirements under Rule 38 of the Rules of Court. For it to prosper, the petitioner must convincingly establish that the judgment was entered against him through fraud, accident, mistake, or excusable negligence, and he must file the petition within sixty days after learning of the judgment and within six months after its entry. Crucially, the petition must be accompanied by an affidavit of merit detailing the facts constituting the claimed fraud, accident, mistake, or excusable negligence, as well as the petitioner’s substantial defense.
The Court found that Samonte’s petition was fatally defective. He failed to allege any of the grounds for relief, such as excusable negligence for his failure to appeal. His petition focused solely on the alleged substantive error in holding him solidarily liable, which is a matter of defense, not a ground for relief. By omitting the required affidavit of merit explaining the circumstances of his default and his valid defenses, he did not comply with the mandatory procedural rules. The Court held that strict compliance with these rules is indispensable for the orderly administration of justice. A meritorious defense alone cannot justify relief when the petitioner has displayed indifference to procedural requirements, especially after a judgment has attained finality.