Ramos vs. Ramos

A final and executory judgment is immutable and unalterable; it may be set aside only on grounds of clerical error, nunc pro tunc entries causing no prejudice, or voidness. In an action to determine ownership of real property—categorized as quasi in rem—personal service of summons upon every heir of a deceased registered co-owner is not required where the estate of the decedent has been made a party and served. The estate’s representation suffices to bind the heirs, particularly under the representative-party rule of the 1964 Rules of Court.

Paulino V. Chanliongco Jr., together with his siblings Narcisa, Mario, and Antonio, co-owned a parcel of land in Tondo, Manila. A Special Power of Attorney executed by the co-owners in favor of Narcisa led to the sale of the entire lot by Narcisa’s daughter, Adoracion C. Mendoza, to the respondents. Conflicts among the heirs of the co-owners regarding the sale’s validity prompted respondents to file a complaint for interpleader. The trial court validated the sale only as to Narcisa’s share, but the Court of Appeals modified the decision, ruling the sale valid for all co-owners because Adoracion acted as a duly authorized sub-agent of her mother. That CA decision became final and executory. Years later, the children of Paulino Chanliongco moved to set aside the final decision, alleging that they had never been made parties nor served summons and that the disposition of their father’s share without their participation was void for lack of due process.

• The Property and the Co-Owners: The dispute concerns Lot No. 2-G of Subdivision Plan SWO No. 7308, situated in Tondo, Manila. The registered co-owners were siblings Paulino V. Chanliongco Jr., Narcisa Chanliongco, Mario Chanliongco, and Antonio Chanliongco.
• The Sale Transaction: By virtue of a Special Power of Attorney executed by the co-owners in favor of Narcisa alone, her daughter Adoracion C. Mendoza sold the entire lot to respondents on different dates in September 1986. Conflict among the heirs of the co-owners as to the validity of the sale prompted respondents to file a complaint for interpleader.
• RTC and CA Rulings: The RTC upheld the sale only as to Narcisa’s share, finding that Adoracion lacked authority to sell the shares of the other co-owners. On appeal, the CA ruled that Adoracion acted as a sub-agent of Narcisa, obviating the need for a separate special power of attorney; the sale was therefore valid as to all co-owners. The CA Decision, dated September 28, 1995, was not appealed and attained finality on August 8, 1996.
• Petitioners’ Belated Challenge: Petitioners are the children of the late Paulino V. Chanliongco Jr. On April 10, 1999, they filed a Motion to Set Aside the CA Decision, arguing that they were never impleaded as parties in the RTC case, were never served a copy of the complaint or summons, and were thus deprived of due process. They contended that the decision, which disposed of their father’s share in the property, was void for want of jurisdiction over their persons.
• Respondents’ Opposition: Respondents opposed the motion, asserting that the remedy was not allowed under the 1997 Rules of Civil Procedure, the decision had been final and executory for several years, the movants lacked legal standing, and the motion was purely dilatory. The CA denied the motion on those grounds.

• Due Process and Jurisdiction: Petitioners argued that the lower court never acquired jurisdiction over their persons because they were neither impleaded as defendants nor served with summons. They maintained that the CA Decision, which effectively passed their property rights to respondents, was void for having been rendered without due process of law.

• Procedural and Substantive Grounds: Respondents countered that the motion to set aside was not an available remedy under the 1997 Rules of Civil Procedure. They argued that the CA decision had long become final and executory and could no longer be disturbed. Respondents further contended that petitioners had no legal standing because the action was quasi in rem, and service upon the estate of the deceased Paulino Chanliongco was sufficient to bind all heirs.

• Validity of Final Judgment/Denial of Due Process: Whether the Court of Appeals’ Decision dated September 28, 1995 is void for lack of jurisdiction over the persons of petitioners, who were not impleaded as parties or served summons, thereby depriving them of due process.

• Validity of Final Judgment/Denial of Due Process: The CA Decision was not void. Final judgments are immutable; the only exceptions are clerical errors, nunc pro tunc entries causing no prejudice, and void judgments. The underlying action—an interpleader to determine ownership of real property—was a real action quasi in rem, affecting title to or possession of land and not directed against any personal liability. In such actions, personal service upon all individual heirs is not required. The registered co-owners were deceased, and the estate of Paulino Chanliongco, represented by Sebrio Tan Quiming and Associates, was impleaded as defendant and served with summons. Under Section 3, Rule 3 of the 1964 Rules of Court, an executor or administrator could sue or be sued without joining the beneficiary. Petitioners, as mere heirs with an inchoate interest, had no standing to be impleaded separately because the estate already stood for them. Their non-joinder and lack of personal summons did not vitiate jurisdiction. With respect to petitioner Florencio D. Chanliongco, who was actually named in the complaint but not personally served, service upon the estate was sufficient because the estate appeared on behalf of all heirs. Additionally, petitioners’ counsel was a partner in the law firm that represented the estate, making notice to the firm adequate. The final judgment therefore remained valid and immutable.

• Immutability of Final Judgments — A decision that has acquired finality is immutable and unalterable; it may no longer be modified even to correct erroneous conclusions of fact or law. The only recognized exceptions are (1) correction of clerical errors, (2) nunc pro tunc entries that cause no prejudice to any party, and (3) void judgments. Here, because the judgment was not void, the doctrine barred the motion to set aside.
• Classification of Actions and Summons — An action to determine ownership of real property is a real action quasi in rem; it is directed against the thing itself and seeks to subject a person’s interest in the property to a lien or obligation rather than to establish personal liability. In such an action, personal service of summons on every individual claimant is not indispensable. Where the estate of a deceased registered owner has been made a party and duly served, the heirs are bound without each being individually impleaded.
• Representative Parties under the 1964 Rules — Under Section 3, Rule 3 of the 1964 Rules of Court, an executor or administrator may sue or be sued without joining the party for whose benefit the action is prosecuted or defended. This rule allowed the estate of Paulino Chanliongco to litigate on behalf of all his heirs, including petitioners, rendering their individual joinder and personal service of summons unnecessary.

• “Well-settled is the rule that a final judgment is immutable and unalterable. The only exceptions to this rule are (1) the correction of clerical errors, (2) the so-called nunc pro tunc entries which cause no prejudice to any party, and (3) void judgments.” — This passage states the controlling doctrine and why the attack on the final decision could succeed only if the judgment were void.
• “The Complaint filed by respondents with the RTC called for an interpleader to determine the ownership of the real property in question. … It was therefore a real action, because it affected title to or possession of real property. … Thus, there was no need to implead them as defendants in the case, inasmuch as the estates of the deceased co-owners had already been made parties.” — This reasoning links the nature of the action to the permissibility of omitting individual heirs from the suit.

• Salva v. Court of Appeals, 304 SCRA 632; Nacuray v. National Labor Relations Commission, 270 SCRA 9; Nuñal v. Court of Appeals, 221 SCRA 26 — relied upon to establish and reiterate the rule on the immutability of final judgments and its exceptions.
• Asiavest Limited v. Court of Appeals, 296 SCRA 539 — cited for the definitions of actions in personam, in rem, and quasi in rem, and for the principle that service of summons in quasi in rem actions does not require personal jurisdiction over the defendant in the same manner as in personam actions.
• Papa v. A.U. Valencia and Co., Inc., 284 SCRA 643 — invoked to confirm that under Section 3, Rule 3 of the old Rules, an executor or administrator may sue or be sued without joining the beneficiary.
• Pascual v. Pascual, 73 Phil. 561 — cited for the rule that heirs have no standing to sue with respect to property of the estate while the estate is represented by an executor or administrator.

• Section 3, Rule 3 of the 1964 Rules of Court — Provided that a trustee, guardian, executor, or administrator may sue or be sued without joining the party for whose benefit the action is prosecuted or defended. The Court applied this provision to hold that the estate of Paulino Chanliongco, represented by its counsel, was the proper party defendant, and its service with summons was sufficient to bind all the heirs, including petitioners.
• Section 3, Rule 3 of the 1997 Rules of Court — While the present rule requires joinder of the beneficiary, it was noted only by way of contrast; the complaint was filed when the 1964 Rules were still in effect, and the old provision governed the necessity of impleading the heirs.

Puno, Sandoval-Gutierrez, Corona, and Carpio-Morales, JJ., concur.