Spouses Marcelo G. Flores and Medelyn Flores vs. Spouses Leopoldo A. Estrellado and Enriqueta Estrellado, et al.

Denial of due process is a ground for annulment of judgment under Rule 47, in addition to extrinsic fraud and lack of jurisdiction, and it is violated when a litigant is represented by counsel who are disbarred or suspended, or whose gross, palpable, and inexcusable negligence or fraud deprives the litigant of the day in court; the right to counsel in civil cases must be exercised at every step of an ongoing litigation.

Petitioners Spouses Marcelo G. Flores and Medelyn Flores were borrowers and mortgagors of respondent Spouses Leopoldo A. Estrellado and Enriqueta Estrellado, who were the lenders and mortgagees. The other respondents were lawyers who became involved in petitioners' litigation against the Estrellados. The case arises under Rule 47 of the Rules of Court, which governs annulment of judgment and generally limits its grounds to extrinsic fraud and lack of jurisdiction, subject to the Court's recognition of denial of due process as an additional ground.

In December 2005, petitioners Spouses Marcelo G. Flores and Medelyn Flores contracted a loan from respondent Spouses Leopoldo A. Estrellado and Enriqueta Estrellado in the amount of P3,000,000.00. The loan was due in six months and earned 3.5% interest a month. Petitioners paid the monthly interest of P105,000.00 from February 2006 up to May 2006. On June 30, 2006, they obtained a second loan of P2,500,000.00 from Spouses Estrellado, and the latter agreed to defer the collection of interests on both loans until the second loan matured in a year. To cover the loans, petitioners signed a Kasulatan ng Sanglaan offering their 1,505-square-meter residential house and lot in Barangay San Agustin, Alaminos, Laguna, registered under TCT T-5473324, as security.

Despite the agreement to defer payments, petitioners received demand letters from Spouses Estrellado even before the second loan became due. Spouses Estrellado sought to collect 42% interest per annum on both loans without deducting or specifying the payments petitioners had already made. Petitioners later discovered that their mortgaged property had been foreclosed and sold at public auction. They engaged the services of Atty. Bede Tabalingcos to protect their rights. On March 3, 2009, Tabalingcos filed a complaint to nullify the loan documents and foreclosure proceedings, docketed as SP 6569(09), which was raffled to RTC Branch 32, San Pablo City, Laguna, and submitted for decision on October 23, 2013.

Unknown to petitioners, the Court had disbarred Tabalingcos in its Decision dated July 10, 2012 in A.C. No. 6622. They were also unaware that on December 12, 2012, Tabalingcos withdrew as their counsel in SP 6569(09) and that his supposed law office partner, Atty. Cres Dan D. Bangoy, entered his appearance as their new lawyer in lieu of Tabalingcos. Petitioners never engaged Bangoy and knew nothing of him except Tabalingcos' representation that he was his law office partner. As far as petitioners were concerned, Tabalingcos was their true lawyer; he continued to act as their counsel and receive fees from them, and they were never made aware of his disbarment. Bangoy nevertheless filed pleadings on their behalf, including their Comment on Spouses Estrellado's formal offer of evidence. Meanwhile, one Atty. Raymond Caraos filed a Memorandum in SP 6569(09) on their behalf although he was a stranger to them. Tabalingcos used the credentials of Bangoy and Caraos to continue representing petitioners despite his disbarment. Petitioners were never duly represented from the time Tabalingcos withdrew his representation on December 12, 2012 until the case was submitted for decision in October 2013.

By Joint Decision dated December 16, 2013, the trial court dismissed SP 6569(09). It declared the extrajudicial foreclosure proceedings in EJF 3189, including the Amended Certificate of Sale issued on April 8, 2008, valid and legal, and directed petitioners to pay Spouses Estrellado P100,000.00 as temperate damages and P50,000.00 as attorney's fees. Tabalingcos assured petitioners that the dismissal was only a minor setback and that he would file a motion for reconsideration. By Order dated March 10, 2014, however, the trial court denied reconsideration. Petitioners secured a copy of their supposed motion for reconsideration and discovered that it was signed by a certain Socrates R. Rivera, whom they did not know and had not engaged. When asked, Tabalingcos said Rivera was one of his associates. Tabalingcos again reassured petitioners that the rulings could still be rectified through an appeal. On March 21, 2014, a notice of appeal was filed on their behalf, again signed by Rivera. Their appeal, CA GR CV No. 102852, was dismissed under Resolution dated February 12, 2015 for failure to file their appellants' brief. When confronted, Tabalingcos made convoluted excuses such as the destruction of his law office and loss of case records, and promised that a motion for reconsideration would be filed. That motion was denied under Resolution dated February 3, 2016.

Tabalingcos represented that he would file a petition for review before the Court, but petitioners were surprised to learn that on February 25, 2016, a motion for extension was filed not by Tabalingcos but by Rivera. Under Resolution dated April 18, 2016 in G.R. No. 222917, the Court denied their supposed appeal for failure to show that the Court of Appeals erred in CA G.R. CV No. 102852, and noted their counsel's failure to state the material dates and submit a soft copy of their petition as required under A.M. No. 11-9-4-SC or the Efficient Use of Paper Rule. No longer satisfied with Tabalingcos' excuses, petitioners sought a meeting with Rivera, who denied any knowledge or involvement in their case. According to Rivera, his signatures in all the pleadings filed on their behalf were forged, and he never worked for Tabalingcos as an associate. Petitioners thus claimed they were defrauded into believing that Tabalingcos was a lawyer of good standing and that he was effectively representing their cause with the help of his supposed associate. In truth, Tabalingcos had not been a member of the bar since July 10, 2012, when the case was still pending with the trial court; on appeal, he continued to represent petitioners using Rivera's credentials and forged signatures.

Desperate and still reeling from Tabalingcos' betrayal, petitioners looked to Rivera to rectify the situation. Rivera agreed to take on their case and informed them that he would move for reconsideration before the Court and oppose the execution of the trial court's judgment. Instead, Rivera filed a Complaint dated July 12, 2016 with the Court of Appeals, seeking to nullify their loan agreement with Spouses Estrellado and for proper accounting. Rivera subsequently furnished petitioners a copy of a Resolution dated November 5, 2016, purportedly of the Court of Appeals in CA G.R. CV No. 102852, which declared the foreclosure proceedings and all proceedings before the RTC null and void and remanded the case to the RTC. Rivera explained that he had obtained a favorable decision. In 2018, Rivera furnished petitioners copies of a Manifestation dated January 18, 2018 and a Comment dated April 16, 2018, which he allegedly filed before the Court of Appeals in relation to CA GR CV No. 102852; these documents stated that the Court had remanded the case to the Court of Appeals in 2016. Rivera also supposedly filed a Compliance Cum Manifestation dated July 14, 2018 in G.R. No. 210091-12, informing the Court that petitioners were actually Tabalingcos' clients and that Tabalingcos had forged Rivera's signature when he supposedly appealed from the dispositions of the Court of Appeals in CA G.R. CV No. 102852. Petitioners, not learned in the law or legal practice, believed all of Rivera's representations.

On December 7, 2018, petitioners received the trial court's Order dated October 23, 2018 directing the issuance of a writ of execution to implement its earlier Joint Decision dated December 16, 2013. Surprised, they asked Rivera how the trial court could have issued such a writ when the Court of Appeals had already nullified the mortgage over their property. Rivera answered that he would move for reconsideration and thereafter filed a Motion to Implement the Court of Appeals' purported Resolution dated November 5, 2016. By Order dated November 20, 2018, the trial court denied reconsideration. Before ruling on the merits, it noted that Rivera sought conflicting relief: he prayed that Spouses Estrellado's motion for execution be granted and at the same time that the Order dated October 23, 2018 on the issuance of a writ of execution be set aside. This was the final straw. Petitioners investigated Rivera's legal standing and discovered that the Court had suspended Rivera from the practice of law for three years under Resolution dated August 9, 2016 in A.C. No. 11350. Hence, he could not have lawfully represented them in the proceedings nor filed any pleading on their behalf. With the aid of their new counsel, they secured a certification from the Judicial Records Division of the Court of Appeals that all pleadings Rivera allegedly filed on their behalf were spurious. The Court also took judicial notice of its Decision dated November 3, 2020 in A.C. No. 11241, which ordered the disbarment of Rivera.

• Denial of Right to Counsel and Due Process: Petitioners maintained that the right to be assisted by counsel includes the right to be assisted by a member of the bar in good standing; since their so-called counsels were either disbarred or suspended while handling their cases, they were essentially deprived of their right to counsel and denied due process of law.
• Absence of Negligence: Petitioners argued that, contrary to the Court of Appeals' ruling, they consistently and persistently monitored their case; they confronted Tabalingcos on the personality of Rivera to file pleadings on their behalf and on his failure to file their brief, and they could not have guarded against the cunning misrepresentations of their so-called counsels.
• Vulnerability and Reliance on Counsel: Petitioners asserted that they were an elderly couple with low education whose only guidance was that of their lawyers, and that they should not be faulted for failing to ask whether their lawyers were suspended or disbarred.
• Annulment of Judgment and Relief: Petitioners sought annulment of the trial court's Decision dated December 16, 2013 and Order dated October 23, 2018 in SP 6569(09), alleging they were deprived of their day in court by their so-called counsels, and prayed for injunctive relief and sanctions against the lawyers.

• Factual Issues: Spouses Estrellado riposted that the petition raises factual issues which the Court may not entertain.
• Petitioners' Own Fault: They agreed with the Court of Appeals' finding that the supposed denial of due process was due to petitioners' own fault.

• Due Process and Right to Counsel: Whether petitioners were denied due process of law when they were represented by counsel who were either disbarred or suspended from the practice of law.
• Annulment of Judgment Ground: Whether denial of due process, including denial of the right to counsel, is a ground for annulment of judgment under Rule 47 of the Rules of Court.
• Negligence of Petitioners: Whether the Court of Appeals correctly dismissed the petition for annulment of judgment on the ground that petitioners were negligent in monitoring their case.
• Factual Findings in Petition for Review: Whether the Court may re-examine the factual finding of petitioners' negligence in a petition for review on certiorari.
• Relief: Whether the RTC Joint Decision dated December 16, 2013 and related issuances should be annulled or declared void.

• Due Process and Right to Counsel: Yes. Petitioners were denied due process; they were represented by disbarred or suspended lawyers and, in reality, had no counsel at all. The right to counsel in civil cases must be exercised at every step of an ongoing litigation.
• Annulment of Judgment Ground: Yes. Although Rule 47 limits annulment to extrinsic fraud and lack of jurisdiction, Arcelona vs. Court of Appeals recognized denial of due process as a third ground; proceedings where a party was not duly represented by counsel may be annulled.
• Negligence of Petitioners: No. Petitioners consistently monitored and confronted their counsel; they were not learned in law, of advanced age, and could not have guarded against the fraud. They were not negligent.
• Factual Findings in Petition for Review: Yes. The Court may re-examine the finding because the Court of Appeals' judgment was based on a misapprehension of facts, notwithstanding the general rule that only questions of law are entertained.
• Relief: Petition granted; the Court of Appeals resolutions were reversed and set aside; the RTC Joint Decision and all related issuances were declared void.

• Due Process and Right to Counsel: The Court began by noting that the issue of whether petitioners were negligent in monitoring their case is a purely factual issue. As a general rule, only questions of law may be entertained in a petition for review on certiorari, and findings of fact of the Court of Appeals are conclusive and binding. Where the judgment is based on a misapprehension of facts, however, the Court has the bounden duty to re-examine the evidence on record. On the merits, Section 1, Article III of the Constitution provides that no person shall be deprived of life, liberty, or property without due process of law. Collateral to this right is the right to be assisted by counsel for the purpose of ensuring that due process rights of litigants are truly observed. Section 14(2), Article III further mandates that in all criminal prosecutions, the accused shall enjoy the right to be heard by himself and counsel, and there is no reason not to apply this safeguard to civil cases as well. Spouses Telan vs. Court of Appeals held that the right to counsel in civil cases exists just as forcefully as in criminal cases, especially when life, liberty, or property is subjected to restraint or in danger of loss. In criminal cases, the right to be assisted by a member of the bar is immutable; even if the judgment had become final and executory, it may still be recalled and the accused afforded the opportunity to be heard by himself and counsel. There is no reason why the rule in criminal cases has to be different from that in civil cases. The preeminent right to due process applies not only to life and liberty but also to property. There can be no fair hearing unless a party who is in danger of losing his house in which he and his family live and in which he has established a modest means of livelihood is given the right to be heard by himself and counsel. In Spouses Telan, the petitioners lost an accion publiciana case, hired "Atty. Palma" to represent them before the appellate court, but he failed to file the required appeal brief, causing the Court of Appeals to dismiss the appeal. They later discovered that "Atty. Palma" was not in the Roll of Attorneys. The Court, taking into account the denial of due process, granted the appeal and reinstated the proceedings before the Court of Appeals. In Polsotin, Jr. vs. De Guia Enterprises, Inc., petitioners' appeal and petition for certiorari before the National Labor Relations Commission and the Court of Appeals were dismissed on purely technical grounds, but the Court noted that petitioners were not represented by a lawyer, had no counsel on record, and had been filing and signing all pleadings only through a co-party. The Court held that petitioners' procedural lapses ought to be excused and the proceedings before the labor arbiter reinstated. The Court emphasized that the right to counsel, being intertwined with the right to due process, is guaranteed by the Constitution in administrative, civil, or criminal proceedings, and that the Court of Appeals should have extended some degree of liberality to give the party a chance to prove their cause with a lawyer. Thus, a violation of a person's right to be heard by counsel is tantamount to a violation of the right to due process, and following Arcelona, proceedings wherein one or both parties were not duly represented by counsel may be susceptible to annulment of judgment under Rule 47. The Court also held that just because a party is assisted by counsel does not automatically mean that the right to counsel and due process are observed; where counsel commits a mistake so gross, palpable, and inexcusable as to result in violation of the client's substantive rights, such mistake may also constitute a due process violation. In Heirs of Pael vs. Destura, the Court upheld the annulment of the trial court's ruling because therein respondents' former counsel, Atty. Oliver Lozano, failed to file an answer despite the extremely valuable property involved and successively filed inconsistent remedies, which amounted to reckless negligence of counsel grossly violating the respondents' right to due process. Here, petitioners were denied due process because they were represented by counsel who were either disbarred or suspended from the practice. The records bore the systematic way by which petitioners were defrauded by their so-called counsels: Tabalingcos had been disbarred on July 10, 2012 in A.C. No. 6622 but continued to represent petitioners; he withdrew and caused the entry of appearance of Atty. Bangoy, whom petitioners accepted only because Tabalingcos misrepresented him as his law firm partner; petitioners continued to deal only with Tabalingcos and paid him legal fees; Bangoy and Caraos filed pleadings without petitioners' knowledge, and Tabalingcos used their credentials to continue representing petitioners despite his disbarment; Rivera filed a motion for reconsideration, notice of appeal, and petition for review, all while Tabalingcos assured petitioners that Rivera was an associate; Rivera later denied preparing, signing, or submitting any pleadings and denied being Tabalingcos' associate; Rivera then agreed to take the case, filed a Compliance Cum Manifestation stating his signatures were forged, allegedly filed a Complaint with the Court of Appeals, and furnished petitioners with a spurious Resolution; when the trial court sought to implement its decision, Rivera filed a Motion to Implement the purported Resolution but actually sought execution to be granted; and upon denial, petitioners discovered that Rivera had been suspended from the practice of law for three years under Resolution dated August 9, 2016 in A.C. No. 11350. Although on paper petitioners were supposedly represented by Tabalingcos and Rivera throughout the proceedings, the latter had already been disbarred and suspended, respectively, so in reality petitioners had no counsel at all. It may be that Tabalingcos was still a lawyer in good standing when petitioners engaged his services in 2009 until his disbarment on July 10, 2012, but the right to counsel is absolute and may be invoked at all times; more so, in an ongoing litigation, it is a right that must be exercised at every step of the way, with the lawyer faithfully keeping his client company. Hence, despite Tabalingcos' earlier assistance, petitioners were not afforded their day in court. On this ground alone, the trial court's ruling may already be nullified in accordance with Spouses Telan and Polsotin. The Court also found Heirs of Pael applicable because the actuations of Tabalingcos and Rivera constituted not only gross, palpable, and inexcusable mistake or negligence but fraud. Despite Tabalingcos' disbarment, he continued to represent petitioners using the credentials of Bangoy and Caraos, which he could not legally do, for a disbarred lawyer is no longer permitted to practice law either directly or indirectly. Rivera concealed his suspension and continued to lawyer for petitioners post-judgment; he lulled petitioners into believing that he had been diligently attending to their case when the documents he showed them were either spurious or otherwise not sanctioned by the rules. Such legal assistance was ineffectual, if not downright criminal. Petitioners were therefore deprived of their day in court, warranting annulment of the trial court's judgment.
• Annulment of Judgment Ground: A petition for annulment of judgment is a remedy in equity which courts view with an attitude of reluctance as it is an exception to the time-honored doctrine of immutability of final judgments. To prevent parties aggrieved by final judgments, orders, or resolutions from abusing this exceptional remedy, the Court installed safeguards limiting its application under Rule 47 of the Rules of Court. Under the rules, the grounds for annulment are limited to extrinsic fraud and lack of jurisdiction. Arcelona vs. Court of Appeals, however, recognized a third ground: denial of due process. In Arcelona, therein private respondent filed an action against some owners of fishponds he had been tending to and prevailed from the trial court all the way to the Supreme Court. The Arcelonas sought to have the trial court's ruling nullified on the ground that they were indispensable parties over whom the trial court failed to acquire jurisdiction. The Court of Appeals initially denied their petition for failure to invoke a proper ground for annulment. The Supreme Court reversed, holding that annulment of judgment is available when the ruling sought to be nullified is void upon its face or by virtue of its own recitals and records. The records were clear from the beginning that the Arcelonas were co-owners who should have been impleaded as indispensable parties, but they were never made aware of the proceedings until after the case got resolved by the Court. Consequently, they were allowed to assail the trial court's ruling via annulment of judgment. Here, petitioners invoked Arcelona and claimed that they, too, were denied due process of law because the actions of their supposed counsels deprived them of their day in court. The Court agreed. A violation of a person's right to be heard by counsel is tantamount to a violation of the right to due process, and proceedings wherein one or both parties were not duly represented by counsel may be susceptible to annulment of judgment under Rule 47.
• Negligence of Petitioners: Despite the foregoing backdrop, the Court of Appeals outrightly dismissed petitioners' plea for annulment of judgment on the ground that they were supposedly negligent in monitoring their case. On the contrary, petitioners had been in constant communication with Tabalingcos and Rivera for purposes of following up on the status of their case. They confronted Tabalingcos on the personalities of Atty. Bangoy, Atty. Caraos, and Rivera to file pleadings on their behalf only to be told that the three were either law partners or associates. Petitioners also confronted Tabalingcos when he failed to file their brief before the Court of Appeals. When petitioners switched to the services of Rivera, they were never remiss on following up their case with him as well. The level of trickery and falsehood employed by their so-called counsels was something petitioners could not have easily guarded against. The Court could not fault petitioners for relying on the assurances given them. Petitioners were not learned in the law or legal practice and were of advanced age, and they were defenseless against their counsels' fraudulent schemes. Spouses Telan further elucidated that even the most experienced lawyers get tangled in the web of procedure, and to demand as much from ordinary citizens whose only compelle intrare is their sense of right would turn the legal system into an intimidating monstrosity where an individual may be stripped of his property rights not because he has no right to the property but because he does not know how to establish such right. Petitioners raised a valid concern when they asked: when their lawyers gave them a report on their cases and told them of the next legal strategy, who were they to argue otherwise? Petitioners were in no position to analyze the legal niceties of the remedies resorted to by their counsels and to realize the deleterious effects of the latter's tactical errors, more so where the acts of their counsels were tainted not only with gross negligence but with actual fraud committed at the expense of petitioners. In fine, petitioners were denied the most basic right to due process when they got repeatedly deprived of their day in court. Their so-called counsels were no counsel at all. Worse, Tabalingcos and Rivera wasted the finite time and resources of petitioners with their brazen trickery and falsehood. The Court could not give its imprimatur to such vile acts. As discussed by Associate Justice Alfredo Benjamin S. Caguioa during the deliberations, the Court must perform its legal and moral duty to provide judicial aid to parties who are deprived of their rights.
• Factual Findings in Petition for Review: The Court noted that the issue of whether petitioners were negligent in monitoring their case is a purely factual issue. As a general rule, the Court may only entertain questions of law in petitions for review on certiorari; it is not a trier of facts, and findings of fact of the Court of Appeals are conclusive and binding. But where the judgment is based on a misapprehension of facts, as here, it becomes the Court's bounden duty to re-examine the evidence on record for a judicious resolution of the controversy.
• Relief: Because petitioners were denied due process and were not negligent, the petition was granted. The Court of Appeals resolutions dated April 26, 2019 and January 28, 2020 in CA G.R. SP No. 159899 were reversed and set aside. The Joint Decision dated December 16, 2013 of the Regional Trial Court - Branch 32, San Pablo City, Laguna in SP 6569(09) and all related issuances were declared void.

• Denial of Due Process as a Ground for Annulment of Judgment — Rule 47 of the Rules of Court limits annulment of judgment to extrinsic fraud and lack of jurisdiction, but Arcelona vs. Court of Appeals recognized denial of due process as a third ground. Proceedings in which one or both parties were not duly represented by counsel may be annulled under Rule 47. The Court applied this doctrine because petitioners were represented by lawyers who were disbarred or suspended and therefore were no counsel at all.
• Right to Counsel in Civil Cases — The right to counsel in civil cases exists just as forcefully as in criminal cases, especially when life, liberty, or property is subjected to restraint or in danger of loss. It is collateral to the right to due process, and a violation of the right to be heard by counsel is tantamount to a violation of due process. The Court applied this to petitioners, who faced loss of their property through a final judgment while being represented by disbarred or suspended counsel.
• Gross, Palpable, and Inexcusable Negligence or Fraud of Counsel as Due Process Violation — Even when a party is assisted by counsel, due process may be violated where counsel commits a mistake so gross, palpable, and inexcusable as to result in violation of the client's substantive rights. The Court found this doctrine applicable because the actuations of Tabalingcos and Rivera constituted not only gross negligence but fraud, including continued practice after disbarment or suspension and the use of forged signatures and spurious documents.
• Right to Counsel Must Be Exercised at Every Step of an Ongoing Litigation — The right to counsel is absolute and may be invoked at all times. In an ongoing litigation, it must be exercised at every step of the way, with the lawyer faithfully keeping his client company. Thus, even if Tabalingcos was still in good standing when first engaged in 2009, his subsequent disbarment meant petitioners were not afforded their day in court.
• Annulment of Judgment as a Remedy in Equity and Exception to Immutability of Final Judgments — A petition for annulment of judgment is a remedy in equity viewed with reluctance because it is an exception to the doctrine of immutability of final judgments. Safeguards under Rule 47 limit its application, but the Court may grant it where due process was denied.
• Factual Findings of the Court of Appeals; Exception for Misapprehension of Facts — Findings of fact of the Court of Appeals are conclusive and binding, and the Supreme Court is not a trier of facts. However, where the judgment is based on a misapprehension of facts, the Court may re-examine the evidence on record. The Court applied this exception because the Court of Appeals misapprehended the facts regarding petitioners' alleged negligence.

• "A petition for annulment of judgment is a remedy in equity which courts view with an attitude of reluctance as it is an exception to the time honored doctrine of immutability of final judgments." — This passage defines the nature of annulment of judgment and explains why courts limit its application under Rule 47.
• "The right to counsel in civil cases exists just as forcefully as in criminal cases, specially so when as a consequence, life, liberty, or property is subjected to restraint or in danger of loss." — This passage states the Court's basis for extending the right to counsel to civil litigation involving property.
• "Verily, a violation of a person's right to be heard by counsel is tantamount to a violation of said person's right to due process. Thus, following Arcelona, proceedings wherein one or both parties were not duly represented by counsel may be susceptible to annulment of judgment under Rule 47 of the Rules of Court." — This passage is the ratio decidendi linking denial of the right to counsel to annulment of judgment.
• "But just because a party is assisted by counsel in a given case does not automatically mean that his or her right to counsel and due process are observed. For where counsel commits a mistake so gross, palpable and inexcusable as to result in violation of his or her client's substantive rights, such mistake may also constitute due process violation." — This passage establishes that gross negligence or fraud of counsel can itself violate due process.
• "In fine, we agree with petitioners that they were denied the most basic right to due process when they got repeatedly deprived of their day in court. Their so-called counsels were no counsel at all." — This passage summarizes the Court's conclusion on the facts and the due process violation.

• Arcelona vs. Court of Appeals, 345 Phil. 250, 282 (1997) — Recognized denial of due process as a third ground for annulment of judgment, in addition to extrinsic fraud and lack of jurisdiction; relied upon by the Court.
• Spouses Telan vs. Court of Appeals, 279 Phil. 587, 594-595 (1991) — Held that the right to counsel in civil cases exists as forcefully as in criminal cases and that denial of due process may warrant reinstatement of proceedings; followed.
• Polsotin, Jr. vs. De Guia Enterprises, Inc., 677 Phil. 561, 567-568 (2011) — Held that the right to counsel is intertwined with due process and that procedural lapses may be excused where a party was not represented by counsel; followed.
• Heirs of Pael vs. Destura, 382 Phil. 222 (2000) — Held that gross, palpable, and inexcusable negligence or fraud of counsel may violate due process and warrant annulment of judgment; applied.
• Inacay vs. People, 801 Phil. 187, 191-192 (2016) — Cited for the rule that the right to counsel is absolute and must be exercised at every step of an ongoing litigation.
• Gimalay vs. Court of Appeals, G.R. Nos. 240123 & 240125, June 17, 2020 — Cited for the general rule that only questions of law may be entertained in a petition for review on certiorari and that the Court is not a trier of facts.
• Heirs of Villanueva vs. Heirs of Mendoza, 810 Phil. 172, 178-179 (2017) — Cited for the exception that the Court may re-examine factual findings when the judgment is based on a misapprehension of facts.
• Dare Adventure Farm Corporation vs. Court of Appeals, 695 Phil. 681, 688-689 (2012) — Cited for the safeguards limiting the application of annulment of judgment under Rule 47.

• Section 1, Article III, 1987 Constitution — Provides that no person shall be deprived of life, liberty, or property without due process of law. The Court applied this to protect petitioners' property interest in the litigation.
• Section 14(2), Article III, 1987 Constitution — Provides that in all criminal prosecutions, the accused shall enjoy the right to be heard by himself and counsel. The Court held that there is no reason not to apply this safeguard to civil cases as well.
• Rule 47, Section 2, Rules of Court — Provides that annulment of judgment may be based only on extrinsic fraud and lack of jurisdiction. The Court noted this limitation but recognized denial of due process as a third ground under Arcelona vs. Court of Appeals.
• A.M. No. 11-9-4-SC (Efficient Use of Paper Rule) — Cited in the prior Supreme Court resolution in G.R. No. 222917, which denied petitioners' supposed appeal partly because their counsel failed to submit a soft copy of the petition as required by the rule.

Gesmundo, C.J. (Chairperson), M. Lopez, and J. Lopez, JJ., concur. Caguioa, J., filed a concurring opinion; the text of that separate opinion is not included in the provided source.