GR 77459; (May, 1990) (Digest)
G.R. No. 77459 . May 21, 1990. SPOUSES ELIGIO GUNDAYAO and CRESENCIA BALUYUT, et al., and DIRECTOR OF LANDS, petitioners, vs. COURT OF APPEALS and HEIRS OF POMPELO BALUYUT, et al., respondents.
FACTS
The case involves a 2.5-hectare parcel of land in Capas, Tarlac, originally declared under Tax Declaration No. 213 in the name of Pompelo Baluyut. Upon his death in 1942, his heirs (respondents) claimed sole ownership by virtue of a 1930 deed of sale and alleged that his siblings (petitioners Cresencia, Florencia, Natividad, and Ricardo Baluyut) were merely allowed to stay on the land during the war. The petitioners, however, asserted co-ownership, claiming the land was inherited by their father, Aquilino Baluyut, from Celestino de Lara in 1913. In 1968, the petitioners subdivided the land and obtained free patents and Original Certificates of Title (OCTs) in their individual names.
The heirs of Pompelo Baluyut filed an action for reconveyance and annulment of titles. The trial court ruled in favor of the heirs, declaring the OCTs null and void, a decision affirmed by the Court of Appeals (CA) on November 19, 1985. The petitioners filed a motion for new trial with the CA, which was denied in a resolution dated January 14, 1987, on the ground that an entry of judgment on the 1985 decision had already been made. The petitioners elevated the matter to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the Court of Appeals committed a reversible error in denying the petitioners’ motion for new trial based on the finality of its 1985 judgment.
RULING
The Supreme Court denied the petition and affirmed the CA resolution. The legal logic is anchored on the doctrine of finality of judgment. The CA’s judgment promulgated on November 19, 1985, had become final and executory, and an entry of judgment was duly recorded. A motion for new trial is a remedy available only before a judgment becomes final. Once a judgment attains finality, it becomes immutable and unalterable. The Court found no compelling reason to disturb this settled rule, as the petitioners failed to demonstrate any exceptional circumstance, such as a lack of jurisdiction or extrinsic fraud, that would warrant a relaxation of the principle.
The Court further noted that the trial court’s decision, which the CA affirmed, was supported by the evidence. It found that the petitioners’ claim of inheritance from their father was not substantiated, whereas the respondents sufficiently proved Pompelo Baluyut’s exclusive ownership through the deed of sale and tax payments. Consequently, the petitioners’ acquisition of titles through free patent was fraudulent, warranting reconveyance. The execution of the judgment, including the cancellation of the void OCTs and the issuance of new titles in the respondents’ favor, had already been carried out, rendering the petition moot. The temporary restraining order was lifted.