G.R. No. 75041 November 13, 1989
Rosa N. Edra, Mercy Edra, Winmelyn Edra, and Jerico Edra, represented by their mother, petitioner Rosa N. Edra, vs. Hon. Intermediate Appellate Court (First Special Cases Division), Marcelino T. Sadumiano alias Mario T. Sadremiano and Pepito N. Zambrana.

FACTS

Petitioners, Rosa N. Edra and her minor children, hired a passenger jeepney owned by respondent Marcelino T. Sadumiano and driven by respondent Pepito Zambrana for a trip to Ilocos Norte. On April 16, 1981, the jeepney met an accident in Bauang, La Union, causing serious injuries to the petitioners. They filed a complaint for damages before the Court of First Instance of Rizal. Summons and a copy of the complaint were served at the respondents’ addresses through Teofila Sadremiano. The respondents failed to file their answers. The trial court declared them in default, allowed ex parte presentation of evidence, and subsequently rendered a decision ordering the respondents to pay jointly and severally P30,000.00 for medical expenses, P10,000.00 as moral damages, and P5,000.00 as attorney’s fees.
Respondent Zambrana later filed a motion to lift the order of default and set aside the decision, claiming lack of jurisdiction due to improper service of summons, alleging Teofila Sadremiano was non-existent and he never received the summons. The trial court denied this motion, ruling the decision had become final and executory, and issued a writ of execution. Subsequently, respondent Sadumiano filed a petition with the Intermediate Appellate Court (IAC) to annul the trial court’s judgment, also alleging improper service. The IAC granted the petition and set aside the trial court’s decision, prompting the petitioners to elevate the case to the Supreme Court.

ISSUE

Whether the Intermediate Appellate Court erred in annulling the trial court’s final and executory judgment based on allegations of improper service of summons.

RULING

Yes. The Supreme Court reversed the IAC decision and reinstated the trial court’s judgment. The core legal principle is the immutability of final judgments. The trial court’s decision became final and executory by operation of law after the lapse of the reglementary period to appeal without any appeal having been perfected. The records showed that respondent Sadumiano had received notice of the judgment. From that notice, the period to appeal began to run. His failure to appeal within that period rendered the judgment final.
A final and executory judgment can no longer be annulled or modified, save for exceptionally meritorious grounds not present here. The doctrine of finality of judgments is grounded on public policy and sound practice, requiring litigation to end at a definite point. The remedy of certiorari cannot substitute for a lost appeal. The IAC was therefore deprived of jurisdiction to alter the trial court’s final judgment. The respondents’ procedural maneuvers, filed years after the judgment’s finality, were merely dilatory tactics intended to frustrate execution. While litigation is not a game of technicalities, the rules cannot be ignored at will to prejudice the orderly administration of justice. The trial court’s judgment, based on ex parte evidence attributable to the respondents’ own fault in not answering the complaint, must stand.