The Supreme Court has affirmed that the remedy of annulment of judgment is reserved for exceptional circumstances, primarily when a court lacks jurisdiction or extrinsic fraud is evident. This principle reinforces the immutability of final judgments, ensuring stability and preventing endless litigation. In Abner Mangubat v. Belen Morga-Seva, the Court reiterated that mere errors in judgment are insufficient grounds for annulment; rather, there must be a clear absence of jurisdiction over the subject matter or the parties involved. This decision underscores the importance of adhering to procedural rules and respecting the finality of judicial pronouncements, providing a vital lesson for litigants and legal practitioners alike.

Compromise or Conflict: When Can a Final Judgment Be Challenged?

This case arose from a long-standing dispute between Gaudencio Mangubat and Belen Morga-Seva, which began with a complaint for specific performance in 1974. After a series of appeals, the Regional Trial Court’s (RTC) decision became final. Years later, Gaudencio filed for a revival of the judgment, leading to a Compromise Agreement between him and Belen. The RTC approved this agreement in 2001. However, after Gaudencio’s death, his son Abner sought to annul the RTC’s final order, arguing that the court had lost jurisdiction. The central legal question became whether the RTC’s subsequent actions were valid, despite the finality of the initial judgment and the subsequent compromise agreement.

The Supreme Court firmly rejected Abner’s arguments, emphasizing that annulment of judgment is an extraordinary remedy, available only under specific conditions. The Court underscored that a judgment may only be annulled based on lack of jurisdiction or extrinsic fraud. According to the Court, “[t]he remedy of annulment of judgment is only available under certain exceptional circumstances as this is adverse to the concept of immutability of final judgments. Hence, it is allowed only on two grounds, i.e., extrinsic fraud and lack of jurisdiction.” Abner contended that the RTC lost jurisdiction after its February 23, 2001 Decision became final, rendering all subsequent actions null and void.

However, the Court clarified the concept of lack of jurisdiction, explaining that it refers to either a lack of jurisdiction over the subject matter or the person of the petitioner. The Court noted that it was “undisputed that the RTC acquired jurisdiction over the person of Abner, he having asked for affirmative relief therefrom several times.” Furthermore, the Court emphasized that jurisdiction over the nature of the action is conferred by law, and the RTC’s jurisdiction over petitions for revival of judgment has already been established. The Court cited previous jurisprudence, stating that “[a]n action for revival of judgment may be filed either ‘in the same court where said judgment was rendered or in the place where the plaintiff or defendant resides, or in any other place designated by the statutes which treat of the venue of actions in general.’” Since the complaint for revival of judgment was filed in the same court that rendered the original decision, the RTC clearly had jurisdiction over the action.

The Supreme Court further elucidated that Abner’s arguments stemmed from a misunderstanding of the distinction between lack of jurisdiction and error in the exercise of jurisdiction. The Court quoted the Court of Appeals’ observation, noting that Abner “clearly confused lack of jurisdiction with error in the exercise of jurisdiction. Jurisdiction is not the same as the exercise of jurisdiction. As distinguished from the exercise of jurisdiction, jurisdiction is the authority to decide a case, and not the decision rendered therein.” Once a court acquires jurisdiction over a case, it retains that jurisdiction until the case is fully resolved. Any errors the court may commit in the exercise of its jurisdiction are merely errors of judgment, which are properly addressed through an appeal.

Even if Abner’s claim of lack of jurisdiction had merit, the Supreme Court held that his petition for annulment was barred by laches. Laches is defined as the failure or neglect, for an unreasonable and unexplained length of time, to do what should have been done earlier, implying that the party entitled to assert a right has abandoned or declined to assert it. In this case, Abner waited almost four years after the finality of the September 25, 2006 Order before bringing an action to annul it, without providing any justification for this delay. This unreasonable delay created a presumption that Abner had relinquished his right to the property. In the Court’s view, “[t]he principle of laches or ‘stale demands’ ordains that the failure or neglect, for an unreasonable and unexplained length of time, to do that which by exercising due diligence could or should have been done earlier ~ negligence or omission to assert a right within a reasonable time, warrants a presumption that the party entitled to assert it has abandoned it or declined to assert it.”

Moreover, the Court clarified that a petition for annulment of judgment is not the proper remedy for an interlocutory order like the September 25, 2006 Order. An interlocutory order is a ruling that addresses a specific point or matter during the course of a lawsuit but does not constitute a final adjudication of the claims and liabilities of the parties involved. The September 25, 2006 Order merely facilitated the transfer of title to Belen, aligning with the final and executory February 23, 2001 RTC Decision, after Abner’s refusal to comply with the directive to deliver the owner’s copy of the title. The Court explicitly stated, “[a]n interlocutory order refers to a ruling respecting some point or matter between the commencement and end of the suit, but is not a final adjudication of the claims and liabilities of the parties that are in dispute in that suit.”

FAQs

What was the key issue in this case?	The key issue was whether the Regional Trial Court (RTC) lost jurisdiction over the case after its initial decision became final, thereby invalidating subsequent orders related to the execution of a compromise agreement.
What is annulment of judgment, and when is it appropriate?	Annulment of judgment is an extraordinary remedy available only when a court lacks jurisdiction over the subject matter or there is extrinsic fraud. It is not a substitute for appeal and cannot be used to correct errors of judgment.
What is the difference between lack of jurisdiction and error in the exercise of jurisdiction?	Lack of jurisdiction means the court does not have the legal authority to hear the case, while error in the exercise of jurisdiction means the court made a mistake while having the authority to hear the case. The former can be grounds for annulment, but the latter requires an appeal.
What is laches, and how did it apply in this case?	Laches is the unreasonable delay in asserting a right, which can prevent a party from seeking relief. In this case, Abner’s delay of almost four years in challenging the RTC’s order was deemed unreasonable, barring his claim.
What is an interlocutory order, and why is it relevant here?	An interlocutory order is a ruling that does not fully resolve the issues in a case. The September 25, 2006 Order was considered interlocutory because it merely facilitated the transfer of property title, not a final adjudication of claims, meaning it couldn’t be challenged via annulment of judgement.
What was the significance of the Compromise Agreement in this case?	The Compromise Agreement, approved by the RTC, settled the dispute between the parties. It became the basis for subsequent orders aimed at its execution, reinforcing the finality of the agreed-upon terms.
What was Abner Mangubat’s main argument for seeking annulment?	Abner argued that the RTC lost jurisdiction over the case once the February 23, 2001 Decision became final, making the subsequent order to transfer the property title void.
How did the Supreme Court rule on Abner Mangubat’s petition?	The Supreme Court denied Abner’s petition, holding that the RTC had jurisdiction, Abner’s claim was barred by laches, and annulment was not the proper remedy for an interlocutory order.

In conclusion, the Supreme Court’s decision in Mangubat v. Morga-Seva reinforces the principles of finality of judgments and the limited scope of annulment as a remedy. Litigants must be diligent in pursuing their claims and remedies within the prescribed legal framework; failure to do so may result in the loss of their rights. The Court’s ruling provides clarity on the importance of jurisdiction, the consequences of delay, and the proper avenues for challenging court orders.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Abner Mangubat, vs. Belen Morga-Seva, G.R. No. 202611, November 23, 2015