G.R. No. 186610 ; July 29, 2013
Police Senior Superintendent Dimapinto Macawadib, Petitioner, vs. The Philippine National Police Directorate for Personnel and Records Management, Respondent.

FACTS

Petitioner, a Police Senior Superintendent, was listed for compulsory retirement on January 11, 2002, as PNP records indicated his birth year as 1946. To avoid retirement, he filed an application for late birth registration in September 2001, declaring his birth year as 1956. Subsequently, he filed a Petition for Correction of Entry in his Public Service Records with the Regional Trial Court (RTC) of Marawi City. The RTC granted the petition in December 2001, ordering the PNP, NAPOLCOM, and CSC to correct his birth date to January 11, 1956. The decision became final and was executed, with the PNP correcting his records.
In 2008, the PNP Directorate for Personnel and Records Management (PNP-DPRM) filed a Petition for Annulment of Judgment with the Court of Appeals, arguing the RTC never acquired jurisdiction over it as an indispensable party that was not impleaded. The CA granted the petition, nullified the RTC decision, and permanently enjoined petitioner from extending his service beyond the mandatory retirement age.

ISSUE

Whether the Court of Appeals correctly annulled the RTC decision for lack of jurisdiction due to the non-joinder of the PNP-DPRM as an indispensable party.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s ruling, holding that the PNP-DPRM was an indispensable party to the correction proceedings. An indispensable party is one without whom no final determination can be had of an action, and whose interest in the subject matter is so material that a judgment would necessarily affect it. The petition sought to compel the correction of official records held in the custody of the PNP, NAPOLCOM, and CSC. The PNP-DPRM, as the custodian of petitioner’s service records, had a direct and substantial interest in the outcome. Any court order mandating a change in these records would impose a legal duty upon the PNP-DPRM and directly affect its administrative functions, including the enforcement of retirement laws.
Since the PNP-DPRM was not impleaded in the RTC petition, the trial court never acquired jurisdiction over it. Consequently, the judgment rendered was void for lack of jurisdiction over an indispensable party. The finality and execution of the RTC decision did not cure this fatal jurisdictional defect. A void judgment can be assailed at any time. The Court also noted the substantive merits, finding petitioner’s evidence for the correction—primarily affidavits—insufficient to overcome the consistent documentary evidence (like his marriage certificate and school records) supporting the 1946 birth year.