G.R. No. L-16056; May 31, 1961
LUZ BALLESTEROS, ET AL., plaintiffs-appellants, vs. OLIVA CAOILE, ET AL., defendants-appellees.

FACTS

Plaintiffs-appellants Luz Ballesteros, et al., filed an action in the Court of First Instance of Pangasinan seeking to be declared owners of a parcel of land, the cancellation of the original certificate of title issued in the name of defendants-appellees Oliva Caoile, et al., and the execution of a deed of reconveyance with damages. The defendants asserted that the complaint failed to state a cause of action and that the action had prescribed. After trial, the court dismissed the complaint, prompting this appeal.
The dispute originated from a prior land registration case. On November 1, 1947, the plaintiffs filed an application for registration of the same land. The defendants opposed it. The hearing was postponed multiple times upon the instance of the plaintiffs’ counsel, with the final postponement being “until further assignment.” The court later set the hearing for September 8, 1949. Despite due notice to their counsel, the plaintiffs and their counsel failed to appear on that date. Consequently, the court dismissed their application, allowed the oppositors (defendants) to present evidence, and subsequently rendered a decision decreeing registration of the land in the defendants’ favor.

ISSUE

Whether the trial court erred in dismissing the plaintiffs’ complaint for reconveyance, considering their claim that the judgment in the prior registration case was null for having been rendered without giving them their day in court due to alleged lack of notice.

RULING

The Supreme Court affirmed the dismissal, finding no merit in the plaintiffs’ appeal. The legal logic centers on the principles of notice, finality of judgments, and laches. The Court held that the plaintiffs were duly notified of the hearing in the registration case through their counsel. Under the Rules of Court, notice to counsel is notice to the client. The record conclusively showed multiple postponements secured by the plaintiffs’ counsel and a final setting with notice properly served. Their failure to appear was therefore attributable to themselves, not to a lack of due process.
The Court further ruled that the remedy against a judgment rendered under such circumstances was a timely petition for relief under Rule 38 of the Rules of Court, which the plaintiffs failed to avail. Instead, they filed the instant action for reconveyance nearly a decade after the registration decree became final. This prolonged inaction constituted laches, a neglect to assert a right within a reasonable time, warranting a presumption that the right has been abandoned. Consequently, the plaintiffs were barred from assailing the final and executory judgment in the registration case through a collateral attack. The decision of the trial court was correct.