GR 193208; (December, 2017) (Digest)
G.R. No. 193208, December 13, 2017
HEIRS OF FERMIN ARANIA, ET AL., Petitioners, vs. INTESTATE ESTATE OF MAGDALENA R. SANGALANG, ET AL., Respondents.
FACTS
Petitioners, claiming to be tenant-tillers since time immemorial, filed an action for recovery of possession of agricultural lands forming part of the estate of Magdalena Sangalang. They presented Certificates of Land Transfer (CLTs) and a Barangay Agrarian Reform Committee certification as proof of their status, alleging they were forcibly ousted in 1987 through coercion and intimidation. They also submitted receipts for lease rentals paid. Respondents countered that the petitioners were not lawful tenants, the BARC certification was falsified as the committee was organized later, and the lands were under Magdalena’s administration.
The Provincial Agrarian Reform Adjudicator ruled for the petitioners, a decision affirmed by the Department of Agrarian Reform Adjudication Board, which held the CLTs and rental receipts substantiated the petitioners’ rights. Respondents filed a petition for review with the Court of Appeals (CA) and a separate petition for certiorari to assail a writ of execution pending appeal. The CA Special Fifteenth Division granted the certiorari petition and nullified the DARAB decision, prompting the petitioners to elevate the case to the Supreme Court via a petition for annulment of judgment.
ISSUE
Whether the Court of Appeals Special Fifteenth Division committed grave abuse of discretion in annulling the final and executory decision of the DARAB.
RULING
Yes. The Supreme Court granted the petition and reinstated the DARAB decision. The Court emphasized that a judgment that has attained finality becomes immutable and unalterable. The DARAB decision had already become final and executory after the respondents’ petition for review before the CA Seventh Division was denied and that denial attained finality. The subsequent petition for certiorari before the CA Special Fifteenth Division, which resulted in the annulment of the DARAB ruling, constituted a prohibited collateral attack on a final judgment.
The legal logic is grounded in the doctrine of finality of judgment and the rule against forum-shopping. The respondents pursued two simultaneous remedies in different CA divisions concerning the same DARAB decision—a petition for review and a petition for certiorari—which is anathema to orderly judicial procedure. The CA Special Fifteenth Division therefore acted with grave abuse of discretion in entertaining the certiorari petition and disturbing a final judgment. The Supreme Court reinstated the DARAB decision ordering the respondents to vacate the landholdings and recognize the petitioners as lawful farmer-beneficiaries, and found the respondents guilty of direct contempt for their procedural tactics.