The Supreme Court has affirmed that actions to revive a judgment must be filed with the Regional Trial Court (RTC), not the Court of Appeals (CA). This ruling clarifies that reviving a judgment is a new action, subject to the RTC’s jurisdiction over civil cases where the subject matter is not easily quantifiable in monetary terms. It emphasizes the importance of understanding jurisdictional rules to ensure legal actions are filed in the correct court.

From Replevin to Revival: Navigating the Jurisdictional Maze

The case began with a loan obtained by Douglas F. Anama from Citibank in 1972, secured by a chattel mortgage over industrial equipment. When Anama defaulted on payments, Citibank initiated a collection suit and replevin action with the Court of First Instance of Manila (now RTC). The RTC issued an Order of Replevin, but the implementation led to a series of legal challenges, including a CA decision nullifying the RTC’s orders of seizure. This CA decision was later affirmed by the Supreme Court.

However, the original records of the case in the RTC were destroyed by fire, leading to a petition for reconstruction of record. Due to the pending appeal before the Supreme Court, the RTC suspended all proceedings in the original case. Years later, Anama filed a petition with the CA to revive the 1982 CA decision, arguing that Citibank’s failure to reconstitute the RTC records constituted abandonment of its claim. The CA denied the petition, stating it lacked jurisdiction, a decision that Anama then appealed to the Supreme Court.

The central issue before the Supreme Court was whether the CA had jurisdiction over the petition for revival of judgment. Anama argued that the revival action should be filed in the same court that rendered the judgment. Citibank, however, contended that jurisdiction lies with the RTC. The Supreme Court sided with Citibank, emphasizing that an action to revive a judgment is a new and independent action.

The Court anchored its decision on Section 6, Rule 39 of the Revised Rules of Court, which distinguishes between execution by motion and execution by independent action. Within five years from the date of entry of a final and executory judgment, execution can be achieved through a simple motion. However, after this period, the judgment is reduced to a right of action that must be enforced through a new complaint filed within ten years from the judgment’s finality.

Sec. 6. Execution by motion or by independent action. – A final and executory judgment or order may be executed on motion within five (5) years from the date of its entry. After the lapse of such time, and before it is barred by the statute of limitations, a judgment may be enforced by action.

The Supreme Court emphasized that a revival suit constitutes a new action. This new action possesses its own cause of action, separate from the original judgment it seeks to revive or enforce. It’s an independent proceeding where the cause of action is the decision itself, not the underlying merits of the original case. The court referenced *Philippine National Bank v. Nuevas*, G.R. No. L-21255, November 29, 1965, 15 SCRA 434, 436-437, to highlight this point, stating it is premised on the assumption that the decision to be revived is already final and executory.

Building on this principle, the Court stated that the rules governing the institution and commencement of actions, including jurisdiction, apply to actions for revival of judgment. Jurisdiction, as the power and authority of courts to hear and decide cases, is determined by the nature of the action as it appears in the complaint. The allegations made in the complaint and the remedies sought dictate the court’s jurisdiction.

The Judiciary Reorganization Act of 1980 (Batas Pambansa Bilang 129), as amended, governs the jurisdiction of courts. Specifically, Section 19 grants the RTC exclusive original jurisdiction over all civil actions where the subject of litigation is incapable of pecuniary estimation. Given that an action to revive a judgment does not involve recovering a sum of money, the Supreme Court concluded that jurisdiction properly lies with the RTC.

This approach contrasts with cases involving specific monetary claims. If the primary objective of an action is the recovery of a sum of money, the claim is considered capable of pecuniary estimation. In such cases, the jurisdiction of the court would depend on the amount being claimed. The present case, however, focuses on the right to enforce a final and executory judgment, making it an action incapable of pecuniary estimation.

Moreover, the Court highlighted the scope of the CA’s jurisdiction as defined in Section 9 of BP 129. The CA’s original jurisdiction is limited to issuing writs of mandamus, prohibition, certiorari, habeas corpus, and quo warranto, actions for annulment of judgments of RTCs, and certain appellate matters. An action for revival of judgment does not fall within this enumeration, further solidifying the conclusion that the CA lacked jurisdiction.

The petitioner, Anama, relied on *Aldeguer v. Gemelo*, 68 Phil. 421 (1939), to argue that the action was correctly filed with the CA. However, the Supreme Court clarified that *Aldeguer* concerned venue, not jurisdiction. Venue, which relates to the proper location for filing a case, is distinct from jurisdiction, which concerns the court’s power to hear and decide a case.

Jurisdiction is a matter of substantive law and cannot be conferred by consent or waiver, whereas venue is procedural and can be waived. The failure to object to improper venue constitutes a waiver of that objection, but jurisdiction cannot be expanded or altered by the parties’ agreement. Therefore, Anama’s reliance on *Aldeguer* was misplaced.

In conclusion, the Supreme Court affirmed the CA’s decision, holding that the petition for revival of judgment was improperly filed with the CA. The Court directed the RTC to proceed with the hearing and disposition of the original civil case, which had been suspended since 1982, with deliberate dispatch.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals (CA) or the Regional Trial Court (RTC) had jurisdiction over a petition to revive a final and executory judgment.
What is an action for revival of judgment?	An action for revival of judgment is a new and independent action brought to enforce a judgment that can no longer be executed by mere motion due to the lapse of time (5 years).
Which court has jurisdiction over an action to revive judgment?	The Supreme Court ruled that the Regional Trial Court (RTC) has jurisdiction over actions to revive judgment, as such actions are considered civil actions where the subject matter is incapable of pecuniary estimation.
Why did the Supreme Court rule that the CA lacked jurisdiction?	The Court of Appeals’ (CA) jurisdiction is limited by law (Batas Pambansa Bilang 129) to specific cases, such as writs of mandamus, prohibition, certiorari, and actions for annulment of RTC judgments, none of which include actions for revival of judgment.
What is the difference between jurisdiction and venue?	Jurisdiction is the court’s power to hear and decide a case, while venue is the place where the case should be heard. Jurisdiction is a matter of law and cannot be waived, while venue is procedural and can be waived.
What happens if a party fails to execute a judgment within five years?	If a party fails to execute a judgment within five years through a motion, they must file a new action to revive the judgment within ten years from the date it became final and executory.
What law governs the jurisdiction of courts in the Philippines?	The jurisdiction of courts in the Philippines is primarily governed by Batas Pambansa Bilang 129, also known as the Judiciary Reorganization Act of 1980, as amended.
Is an action for revival of judgment a new case?	Yes, the Supreme Court clarified that an action for revival of judgment is considered a new and independent action, separate from the original case that led to the judgment sought to be revived.

This case serves as a critical reminder of the importance of adhering to jurisdictional rules when initiating legal actions. The Supreme Court’s decision underscores that actions to revive judgments must be filed with the RTC, ensuring the proper allocation of judicial authority and the efficient administration of justice.

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: Douglas F. Anama v. Citibank, N.A., G.R. No. 192048, December 13, 2017