G.R. No. L-37378. May 30, 1975.
Hideliza C. Camomot and Vicente Mercado, petitioners, vs. Hon. Romulo Senining, Presiding Judge of Branch 1, City Court of Cebu City and Lorenciana P. Mercado, respondents.

FACTS

Respondent Lorenciana Mercado filed a complaint for concubinage against petitioners Hideliza Camomot and Vicente Mercado in the City Court of Cebu. On September 5, 1966, petitioners, assisted by counsel, were arraigned and pleaded not guilty. The case was set for hearing on October 10, 1966, with all parties notified in open court. After trial, the City Court convicted both petitioners. Vicente Mercado appealed to the Court of Appeals, which modified the penalty. This modified decision became final and executory.
The final judgment was set for promulgation in the City Court multiple times but faced repeated postponements sought by petitioners’ counsel. Petitioners then filed the instant petition for certiorari, prohibition, and mandamus. They alleged they were never notified of the September 1966 arraignment, that the trial proceeded without a valid arraignment, and that Hideliza Camomot was absent and unrepresented by counsel during the hearings. They sought to annul all proceedings and the appellate decision.

ISSUE

Whether the proceedings and the resulting final judgment in the concubinage case are void due to alleged lack of proper arraignment and representation of the accused.

RULING

The Supreme Court dismissed the petition. The legal logic is anchored on the conclusive presumption of regularity of judicial proceedings and the finality of judgments. The Court examined the official records, which directly contradicted petitioners’ allegations. The Order of September 5, 1966, and the Certificate of Arraignment of the same date conclusively established that petitioners were duly arraigned with the assistance of counsel. Furthermore, the transcript of stenographic notes from the proceedings confirmed that both petitioners were present, represented by counsel, tried, and convicted.
The Court emphasized that the decision of the Court of Appeals, which affirmed the conviction with modification, had long become final and executory. A final judgment can no longer be disturbed via a collateral attack through a special civil action, especially when the attack is based on factual claims squarely refuted by the record. The petitioners’ belated attempt to question the foundational proceedings, after the judgment had attained finality, constituted an impermissible assault on the integrity and conclusiveness of a final judicial determination. The temporary restraining order was dissolved, and the lower court was directed to proceed with the execution of the final judgment.