Aguila vs. Court of First Instance of Batangas, Branch I, et al.

A final and executory judgment may not be nullified or circumvented through a subsequent action for reconveyance based on the alleged gross ineptitude of counsel; a client is bound by counsel's mistakes, and due process is satisfied by the opportunity to be heard and to have the case reviewed. Reconveyance lies only where property is registered in the name of a non-owner due to mistake or fraud, not to negate a valid final judgment.

Juliana Matienzo had two husbands in succession: Escolastico Alabastro and, after his death, Daniel Aguila. Petitioner Juan Aguila claims the disputed property as the only surviving child of the second marriage, while the private respondents, as children of Maria Alabastro—the sole offspring of the first marriage—resist that claim. The parties had previously litigated the ownership and partition of the same properties in Civil Case No. 1552 before the Court of First Instance of Batangas.

Juliana Matienzo had two husbands in succession: Escolastico Alabastro and, after his death, Daniel Aguila. Juan Aguila claims the disputed property as the only surviving child of the second marriage. The private respondents, as children of Maria Alabastro—the sole offspring of the first marriage—resist that claim.

In an earlier action between them, docketed as Civil Case No. 1552 in the Court of First Instance of Batangas, the private respondents sued for partition and damages against Aguila and his wife, alleging that some properties held by them pertained to the first marriage because Juliana and her second husband had not acquired anything during their marriage. On January 7, 1974, judgment was rendered in favor of the plaintiffs after the defendants were precluded from presenting their own evidence owing to what they later called the gross ineptitude of their counsel, who had failed to appear at two scheduled hearings. A motion for reconsideration and a second motion for reconsideration and/or to present their evidence were both denied. On September 5, 1974, the defendants were given an extension of twenty days to file their record on appeal, and on September 24, 1974, another extension of fifteen days was granted. On November 21, 1974, the trial court denied the defendants' record on appeal and appeal bond on the ground that the decision had already become final and executory. On motion of the plaintiffs, the trial court then issued a writ of execution on December 2, 1974, amended the following day, pursuant to which the properties held by the defendants were levied upon and sold at public auction to the plaintiffs as the highest bidders.

The acts of the trial court were questioned by the defendants in a petition for certiorari and mandamus with preliminary injunction, which was denied by the Court of Appeals. Their motion for reconsideration was also denied. The defendants then came to the Supreme Court in a petition for review by certiorari, which was also denied. An "amended" petition was considered a motion for reconsideration and was likewise denied. On August 16, 1976, another motion for reconsideration was denied with finality, with the warning that no further motions would be entertained.

Nothing daunted, Aguila and his wife tried again, filing on June 8, 1977, a complaint for reconveyance of the properties acquired by the defendants in the earlier action for partition. This new complaint was docketed as Civil Case No. 1728 in the Court of First Instance of Batangas. In their answer, the Hernandez respondents alleged res judicata as one of their affirmative defenses, arguing that the complaint was barred by the prior judgment in Civil Case No. 1552. After preliminary hearing of this defense, the trial court considered the objection well-taken and dismissed the case. Aguila then came to the Supreme Court to challenge the order.

In dismissing the reconveyance complaint, the trial court record showed that when the defendants filed their second motion for reconsideration and/or to allow them to present their evidence, the attached evidence was examined by the court "in fairness to the defendants" but found to be "so vague and not appearing to be indubitable as to warrant reopening of the case." This conclusion was reached by the late Judge Jaime R. Agloro after a careful and lengthy analysis of the evidence, dwelling on each disputed property, its antecedents, description, and the basis of the defendants' claims. The meticulous consideration of such evidence belied the petitioner's complaint that he had been denied due process.

• Res Judicata and Substantial Justice: Petitioner did not seriously dispute that the requisites of res judicata were present, but argued that as a mere technical defense, res judicata should not prevail over his right to substantial justice and due process.
• Due Process: Petitioner claimed he was denied due process when he was deprived of the opportunity to submit his evidence in Civil Case No. 1552 and later to appeal the trial court's decision, due to the gross ineptitude of his original counsel.
• Reconveyance and Equity: Petitioner argued that his counsel's mistakes were correctable in an action for reconveyance, which the Court should allow in the exercise of its equity jurisdiction; he sought reconveyance of the properties allegedly unjustly taken from him. He did not seek nullity of the judgment in Civil Case No. 1552, which had become final due to legal technicality.

• Res Judicata: The Hernandez respondents alleged res judicata as an affirmative defense, arguing that the complaint for reconveyance was barred by the prior judgment in Civil Case No. 1552.

• Res Judicata: Whether the complaint for reconveyance in Civil Case No. 1728 is barred by res judicata by the final judgment in Civil Case No. 1552.
• Due Process: Whether petitioner was denied due process when his counsel failed to present evidence and perfect an appeal in Civil Case No. 1552.
• Reconveyance and Equity: Whether reconveyance may be used to negate a valid final judgment determining ownership, and whether equity may override res judicata and positive law.

• Res Judicata: Yes. The requisites of res judicata are present and petitioner does not seriously dispute them; the final judgment in Civil Case No. 1552 bars the subsequent complaint for reconveyance.
• Due Process: No. Due process guarantees only the opportunity to be heard and to have the decision reviewed; petitioner had that opportunity but forfeited it through his counsel's acts, and the trial court even examined his proffered evidence.
• Reconveyance and Equity: No. Reconveyance is available for mistake or fraud in registration, not to negate a valid final judgment; equity cannot supplant positive law or override res judicata.

• Res Judicata: The ruling set out the requisites: (1) a final former judgment; (2) the court rendering it had jurisdiction over the subject matter and the parties; (3) the former judgment was on the merits; and (4) there was identity of parties, subject matter, and causes of action between the two cases. Petitioner did not seriously dispute their presence. Because the judgment in Civil Case No. 1552 was a valid resolution of the conflicting claims of ownership and had become final, executory, and executed, the complaint for reconveyance was barred. Reconveyance cannot be employed to negate the effects of a valid decision of a court of justice determining ownership in an appropriate proceeding.
• Due Process: Due process guarantees an opportunity to be heard and to have the decision reviewed, not a favorable result. Petitioner had that opportunity but forfeited it through his own counsel, who failed to appear at scheduled hearings, failed to file the record on appeal within the extended period, pursued a wrong remedy before the Court of Appeals and Supreme Court, and allowed the period for relief from judgment to lapse. A client is bound by the acts and mistakes of his counsel and cannot complain that the result might have been different had counsel proceeded differently. Allowing gross ineptitude as a ground to reopen final judgments would lead to endless litigation and render court proceedings indefinite, tentative, and subject to reopening by the mere subterfuge of replacing counsel. Petitioner should have noticed the succession of errors and replaced counsel earlier. Moreover, the trial court examined the proffered evidence and found it vague and not indubitable, so the claim of denial of due process was belied.
• Reconveyance and Equity: Reconveyance is available where, as a result of mistake or fraud, property is registered in the name of a person not its owner; a clerical error in designating the real owner is a valid ground after the decree becomes final following the lapse of one year; and reconveyance may be sought where a person not entitled to the property succeeded in registering it in his name to the prejudice of the real owner. It cannot, however, be used to negate the effects of a valid final judgment determining conflicting claims of ownership. Equity is available only in the absence of law and not as its replacement; it supplements but does not supplant the law. Abstract arguments based only on equity must yield to positive rules, and emotional appeals for justice cannot justify disregard of the law. The applicable maxim is "aequetas nunquam contravenit legis."

• Res Judicata — A final former judgment, rendered by a court with jurisdiction over the subject matter and parties, on the merits, and involving identity of parties, subject matter, and causes of action, bars a subsequent action between the same parties on the same subject matter and cause of action. The Court applied the doctrine because all requisites were present and petitioner did not seriously dispute them; the reconveyance complaint was therefore barred by the final judgment in Civil Case No. 1552.
• Due Process and Binding Effect of Counsel's Mistakes — Due process guarantees only the opportunity to be heard and to have the decision reviewed, not a favorable outcome. A client is bound by the acts and mistakes of counsel; counsel's gross ineptitude does not ordinarily warrant reopening a final judgment, especially where the client continued to retain the same counsel despite a succession of errors. The Court applied this rule to hold that petitioner was not denied due process.
• Reconveyance — Reconveyance is a remedy available where, as a result of mistake or fraud, property is registered in the name of a person not its owner; where there is a clerical error in designating the real owner after the decree becomes final following the lapse of one year; or where a person not entitled to the property succeeded in registering it in his name to the prejudice of the real owner. It cannot be employed to negate the effects of a valid final judgment determining ownership. The Court applied this limitation to bar petitioner's action.
• Equity Cannot Supplant Law (Aequitas Nunquam Contravenit Legis) — Equity is justice outside legality; it is available only in the absence of law and may supplement but not supplant the law. Abstract arguments based only on equity yield to positive rules, and emotional appeals for justice cannot justify disregard of the law. The Court invoked this doctrine to reject petitioner's plea for equitable relief from the final judgment.

• "The petitioner does not seriously dispute that requisites of res judicata are present, to wit: (1) the presence of a final former judgment; (2) the court rendering the same must have jurisdiction over the subject matter and the parties; (3) the former judgment must be on the merits; and (4) there must be, between the two cases, Identity of parties, Identity of subject matter and Identity of causes of action." — States the requisites of res judicata and petitioner's concession, which the Court used to bar the reconveyance complaint.
• "As a matter of fact, he was not denied that opportunity, which is precisely – and only – what due process guarantees." — Defines due process as the opportunity to be heard and to have the decision reviewed, not a guarantee of success.
• "The law on reconveyance is clear, and jurisprudence thereon is well-settled. This remedy is available in cases where, as a result of mistake or fraud, property is registered in the name of a person not its owner." — States the settled rule on reconveyance and its limits.
• "For all its conceded merits, equity is available only in the absence of law and not as its replacement." — Articulates the doctrine that equity cannot supplant positive law, used to reject petitioner's equitable plea.

• Tesoro vs. Court of Appeals, 54 SCRA 296, 304 — Cited for the rule that a client is bound by the action of his counsel and cannot complain that the result might have been different had he proceeded differently; supports the denial of reopening based on counsel's ineptitude.
• Rivero vs. Santos, et al., 98 Phil. 500, 503-504 — Cited within Tesoro for the same principle; mistakes of attorneys are not grounds for a new trial unless the incompetency is so great that the client is prejudiced and prevented from properly presenting his case.
• Bayang vs. Court of Appeals, 148 SCRA 91 — Cited in relation to the requisites of res judicata, along with the cases cited therein.
• Director of Lands, et al. vs. Register of Deeds of Rizal, et al., 92 Phil. 826; Casillan vs. Espartero, et al., 95 Phil. 799; Bustarga vs. Navo, II, 129 SCRA 105; Caragay-Layno vs. Court of Appeals, 133 SCRA 718 — Cited for the law on reconveyance and its availability in cases of mistake or fraud.
• Zabat, Jr. vs. Court of Appeals, 142 SCRA 587 — Cited for the rule that equity yields to positive rules and cannot supplant the law.

Narvasa, Gancayco, and Griño-Aquino, JJ., concurred. Teehankee, C.J., took no part.