G.R. No. 177898 ; August 13, 2008
SIGMA HOMEBUILDING CORPORATION, petitioner, vs. INTER-ALIA MANAGEMENT CORPORATION, DEVELOPMENT BANK OF RIZAL, INTERCON FUND RESOURCES CORPORATION, HASTING REALTY and DEVELOPMENT CORPORATION and REGISTER OF DEEDS for the PROVINCE of CAVITE, respondents.

FACTS

Petitioner Sigma Homebuilding Corporation filed a complaint for annulment of sale, cancellation of titles, and reconveyance against several respondents. It alleged that its assistant vice-president, Augusto S. Parcero, sold its properties in Cavite to Inter-Alia Management Corporation without its knowledge, consent, or a board resolution. Inter-Alia subsequently sold the properties to Development Bank of Rizal (DBR), which then sold them to Intercon Fund Resources Corporation, which in turn conveyed them to Hasting Realty and Development Corporation. Only Hasting filed a motion to dismiss, arguing the complaint stated no cause of action, as annotations on the titles indicated Parcero’s authority and the sale was duly notarized. The Regional Trial Court (RTC) dismissed the complaint against all respondents, not just Hasting, for failure to state a cause of action.
The Court of Appeals (CA) affirmed the RTC’s dismissal. Petitioner’s subsequent petition for review before the Supreme Court was denied, and its motion for reconsideration was denied with finality, with an entry of judgment issued. Undeterred, petitioner filed a petition for annulment of judgment with the CA under Rule 47, which was denied. Petitioner then filed another petition for review with the Supreme Court, which was denied for late filing. After this denial became final, petitioner filed a “letter-appeal” asking the Court to re-examine the merits.

ISSUE

Whether the Supreme Court should entertain petitioner’s letter-appeal, which is essentially a second motion for reconsideration of a final and executory judgment.

RULING

The Supreme Court denied the letter-appeal. Procedurally, the letter-appeal constitutes a prohibited second motion for reconsideration, filed after an entry of judgment had already been made, and is a transparent attempt to evade the effects of a final and executory resolution. The Court emphasized that finality of judgments is a fundamental principle in the administration of justice. Even if procedural rules were to be liberally construed, petitioner’s substantive arguments fail. Petitioner argued it was denied due process when the RTC dismissed the complaint against all respondents motu proprio. The Court held this argument lacked merit. A review of the complaint revealed that the only real parties in interest were petitioner and Hasting, the current titleholder. The other intermediate transferees were not necessary parties, as they stood to neither benefit nor be injured by the judgment. The action’s success hinged solely on the claim against Hasting. Therefore, the RTC’s dismissal of the complaint against all parties was substantively correct, and no deprivation of due process occurred. The Court’s prior resolutions had become immutable.