GR L 48335; (April, 1988) (Digest)
G.R. No. L-48335 April 15, 1988
JUAN AGUILA, petitioner, vs. COURT OF FIRST INSTANCE OF BATANGAS, BRANCH I, SPOUSES JUAN HERNANDEZ and MAGDALENA MALALUAN, et al., respondents.
FACTS
The dispute involves property claims stemming from the successive marriages of Juliana Matienzo. Petitioner Juan Aguila, her child from the second marriage, claims the property. Private respondents, descendants from her first marriage, previously sued for partition in Civil Case No. 1552. In that case, judgment was rendered against Aguila after his counsel failed to appear at hearings, precluding the presentation of his evidence. Motions for reconsideration were denied. Aguila’s subsequent attempts to appeal were thwarted as his counsel failed to file the record on appeal within granted extensions, leading to the decision becoming final and executory. The properties were levied and sold to the respondents. Aguila’s petitions for certiorari and review to the Court of Appeals and Supreme Court were all denied.
Aguila then filed a new complaint for reconveyance (Civil Case No. 1728). The respondents raised the defense of res judicata, arguing the new action was barred by the final judgment in the prior partition case. After a preliminary hearing, the trial court sustained this defense and dismissed the complaint.
ISSUE
Whether the trial court correctly dismissed the complaint for reconveyance on the ground of res judicata, thereby barring Aguila from relitigating the ownership of the properties.
RULING
Yes, the trial court correctly applied the doctrine of res judicata. The petitioner essentially concedes the presence of its requisites: a final former judgment rendered by a court with jurisdiction on the merits, with identity of parties, subject matter, and causes of action between the two cases. His core argument is that res judicata, as a technical defense, should yield to substantial justice and equity due to the denial of due process and the gross ineptitude of his former counsel.
The Court rejected this argument. Due process merely guarantees the opportunity to be heard, not a guarantee of a favorable result. The records established that Aguila had that opportunity in the first case but lost it due to his counsel’s failures. The binding nature of a lawyer’s acts upon the client is a settled rule. The petitioner retained his counsel through multiple unsuccessful proceedings; his forbearance does not negate the finality of the judgment. The remedy of reconveyance is unavailable to nullify a valid and final judicial determination of ownership, as rendered in Civil Case No. 1552. Equity cannot supplant positive law and settled rules on the conclusiveness of judgments. The petition was denied.