G.R. No. 203947; February 26, 2014
RUFA A. RUBIO, BARTOLOME BANTOTO, LEON ALAGADMO, RODRIGO DELICTA, and ADRIANO ALABATA, Petitioners, vs. LOURDES ALABATA, Respondent.

FACTS

Petitioners secured a favorable 1995 RTC decision annulling a deed, ordering reconveyance of property, and awarding damages against respondent. Respondent appealed to the CA but later withdrew, causing the RTC decision to become final and executory on June 20, 1997, with an Entry of Judgment issued on August 20, 1997. Petitioners were represented by the Public Attorney’s Office (PAO). The appealed case was handled by the Special Appealed Cases Division (SAC-PAO) in Manila. The SAC-PAO lawyer in charge resigned in November 1997 without informing petitioners or the local PAO office of the finality. Consequently, petitioners, upon follow-up with their local PAO, were mistakenly told the appeal was still pending.
In November 2007, over ten years after finality, petitioners discovered the Entry of Judgment. They filed an action for revival of judgment in December 2007. The RTC dismissed the case on grounds of prescription, which the CA affirmed, holding that the action was filed beyond the ten-year period from finality allowed for reviving a judgment.

ISSUE

Whether the Court may relax procedural rules on prescription to prevent manifest injustice where the failure to timely execute or revive a judgment is not attributable to the petitioners’ own fault.

RULING

The Supreme Court granted the petition, reversing the CA and RTC. The legal logic proceeds from a strict application of rules to an equitable exception. Under Section 6, Rule 39 and Article 1144(3) of the Civil Code, a final judgment may be executed by motion within five years from entry. After that, it must be enforced by an independent action for revival of judgment within ten years from finality. Technically, petitioners’ 2007 action was filed beyond this ten-year period, warranting dismissal.
However, the Court emphasized that procedural rules are tools to secure, not defeat, substantial justice. The failure to act within the prescriptive period was solely due to the negligence of the PAO lawyer—a government counsel to whom petitioners entrusted their case—and not to petitioners’ own delay or fault. This negligence deprived petitioners of their rightful property victory. The Court, exercising its equity jurisdiction, relaxed the procedural rules. It held that the principle that clients are bound by counsel’s mistakes is not absolute; it yields when its strict application results in the outright deprivation of property and a grave miscarriage of justice. The peculiar circumstances, where petitioners diligently pursued their rights but were misled by their own counsel’s inaction, justified liberality to allow the revival of judgment and prevent a manifest injustice. The case was remanded to the trial court for appropriate action.