Thomas vs. Trono

A judgment attains finality by operation of law upon the lapse of the reglementary period for appeal without any need for a judicial declaration, and once final, the rendering court loses jurisdiction to alter, amend, or modify it — even to correct an erroneous judgment — except in narrowly defined circumstances none of which were present here; moreover, a party with interest in the subject matter who was neither notified nor afforded an opportunity to defend that interest is denied due process, rendering the resulting judgment void for lack of jurisdiction.

Earl Alphonso Thomas, an American citizen, married Rachel Trono on October 7, 1984, and the couple had a son, Earl James Thomas, born August 14, 1985. Alphonso later cohabited with Jocelyn C. Ledres, with whom he had a daughter, Charnnel Shane Thomas, born August 21, 1998, and whom he married on July 22, 2007, in Makati City. Alphonso died on February 12, 2011. The dispute centers on the validity of the RTC's 1997 decision declaring Alphonso's marriage to Rachel void ab initio for being bigamous — a decision that was reversed by the same RTC fourteen years later upon a belated motion for reconsideration by the Office of the Solicitor General, which had not been furnished a copy of the original decision until after Alphonso's death.

Earl Alphonso Thomas, an American citizen, married Rachel Trono on October 7, 1984. The couple had a son, Earl James Thomas, born August 14, 1985. Alphonso later filed a petition for declaration of nullity of his marriage to Rachel before the Regional Trial Court of Makati City, Branch 140. On August 22, 1997, the RTC rendered a Decision declaring the marriage void ab initio on the ground that it was bigamous — Alphonso was still married to Nancy Thomas, also an American citizen. During the trial, Alphonso and Rachel agreed that the properties acquired during their marriage would go to Rachel and Earl. The dispositive portion ordered the Local Civil Registrar of Davao City to cancel the marriage from its Civil Registry. However, the Office of the Solicitor General was not furnished a copy of the Decision.

Relying on the dissolution of his marriage to Rachel, Alphonso cohabited with Jocelyn C. Ledres. Their daughter, Charnnel Shane Thomas, was born on August 21, 1998. On July 22, 2007, Alphonso and Jocelyn married in Makati City to legalize their union and legitimize their child's status. Alphonso died on February 12, 2011. Thereafter, Jocelyn requested certified true copies of the August 22, 1997 Decision, its certificate of finality, and the entry of judgment from the RTC, believing in good faith that the judgment had already attained finality after thirteen years.

Instead of granting the request, the Branch Clerk of Court purportedly discovered that the OSG had not been furnished a copy of the 1997 Decision. The RTC furnished the OSG with a copy and gave it fifteen days from receipt to perfect an appeal or file a motion for reconsideration. The OSG received the Decision on March 8, 2011, giving it until March 23, 2011, to file its motion. On March 28, 2011 — five days beyond the reglementary period — the OSG filed a motion for reconsideration, contending that Alphonso's marriage to Nancy was not proven by competent evidence, that the OSG was not furnished copies of orders and processes, and that the case proceeded without a definitive determination of collusion. The RTC ordered Alphonso to file a comment or opposition within fifteen days from notice. Jocelyn, by counsel, filed a Manifestation and Special Appearance informing the RTC of Alphonso's death, her marriage to him, her lack of knowledge of his marital past, and her inability to locate Alphonso's counsel of record, Atty. Dante C. Contreras. She also asserted the presumption of regularity behind the 1997 Decision and that Alphonso's prior marriage to Nancy was proven by competent evidence.

On June 28, 2011, the RTC granted the OSG's motion, reversed its August 22, 1997 Decision, and ruled that the marriage between Alphonso and Rachel was valid and subsisting. Charnnel, who was a minor at the time of the reconsideration proceedings, was neither made a party to the case nor notified of the proceedings. On September 13, 2017, Charnnel filed a petition for annulment of judgment with the Court of Appeals on the ground of denial of due process, alleging that her parents were lawfully married and lived as a family until Alphonso's death, and that the OSG's motion for reconsideration was belatedly filed beyond the fifteen-day reglementary period, so the RTC no longer had jurisdiction to rule upon it. The CA dismissed the petition on October 10, 2017, holding that the RTC retained jurisdiction because the 1997 Decision had not attained finality due to the failure to furnish the OSG a copy, and that Charnnel was not denied due process because Jocelyn had filed a Manifestation and Special Appearance. Charnnel's motion for reconsideration was denied on July 26, 2018.

• Denial of Due Process: Petitioner maintained that she was not afforded due process when she was not allowed to participate in the proceedings for reconsideration before the RTC, as she never received a copy of the motion for reconsideration despite being an heir of Alphonso with legal standing to assail the marriage.
• Finality of Judgment and Loss of Jurisdiction: Petitioner argued that the OSG's motion for reconsideration was belatedly filed on March 28, 2011, beyond the fifteen-day reglementary period that expired on March 23, 2011, so the August 22, 1997 Decision had already attained finality and the RTC no longer had jurisdiction to alter or reverse it.

• Due Process Observed: The OSG countered that due process requirements were observed considering that Jocelyn was able to file a Manifestation and Special Appearance on the motion for reconsideration, which the CA found sufficient to satisfy procedural due process.

• Legal Standing: Whether Charnnel, as an heir of Alphonso, has legal standing to assail the marriage of Alphonso and Rachel by seeking annulment of the RTC's Order dated June 28, 2011.
• Due Process: Whether Charnnel was denied due process of law when she was neither made a party to the reconsideration proceedings before the RTC nor duly notified thereof, and whether Jocelyn's Manifestation and Special Appearance sufficed to protect Charnnel's interests.
• Finality of Judgment and Jurisdiction: Whether the RTC retained jurisdiction to rule on the OSG's motion for reconsideration and reverse its August 22, 1997 Decision, or whether that Decision had already attained finality by operation of law due to the belated filing of the OSG's motion.

• Legal Standing: Yes. Charnnel, as an heir of Alphonso, is vested with legal standing to assail the marriage of Alphonso and Rachel by seeking annulment of the RTC's June 28, 2011 Order, pursuant to the rule that the death of a party does not extinguish the action for declaration of absolute nullity of marriage as the deceased may have heirs with legal standing.
• Due Process: Yes, Charnnel was denied due process. She was neither made a party to the proceedings nor duly notified, and she was a minor at the time the RTC granted the OSG's motion; Jocelyn's Manifestation and Special Appearance did not directly raise or thresh out Charnnel's interests as Alphonso's heir and thus did not bind or protect her.
• Finality of Judgment and Jurisdiction: No, the RTC no longer had jurisdiction. The OSG's motion for reconsideration was filed on March 28, 2011, beyond the fifteen-day reglementary period that expired on March 23, 2011, so the August 22, 1997 Decision attained finality by operation of law and the RTC lost jurisdiction to alter or reverse it.

• Legal Standing: The Court applied the doctrine from Niñal vs. Bayadog, which held that void marriages governed by the New Civil Code can be questioned even after the death of either party. The death of a party does not extinguish the action for declaration of absolute nullity of marriage because the deceased may have heirs with legal standing to assail the void marriage. Charnnel, as Alphonso's daughter and heir, therefore possessed the requisite standing to file the petition for annulment of judgment challenging the RTC's June 28, 2011 Order that reversed the 1997 Decision.

• Due Process: Due process requires that those with an interest in the subject matter of litigation be notified and afforded an opportunity to defend their interests. Where the denial of the fundamental right of due process is apparent, a decision rendered in disregard of that right is void for lack of jurisdiction. The Court found that Charnnel was neither made a party to the proceedings nor duly notified of the case, and she was a minor at the time the RTC granted the OSG's motion. While Jocelyn filed a Manifestation and Special Appearance, a perusal of that pleading readily showed that Charnnel's interests as Alphonso's heir were not directly raised or threshed out. Jocelyn's appearance therefore should not bind or prejudice Charnnel. To hold otherwise would be tantamount to depriving a then-innocent child, now rightfully asserting her rights, of due process of law.

• Finality of Judgment and Jurisdiction: The Court found that the OSG received a copy of the August 22, 1997 Decision on March 8, 2011, and had until March 23, 2011, to file its motion for reconsideration. The motion was filed only on March 28, 2011, beyond the fifteen-day reglementary period. The 1997 Decision thus became final and executory by operation of law, without need for any judicial declaration or performance of an act. The RTC lost jurisdiction over the case and could no longer alter or reverse the 1997 Decision. The principle of immutability of judgments — interest reipublicae ut sit finis litium — bars modification of a final judgment even to correct an erroneous one, subject only to four exceptions (correction of clerical errors, nunc pro tunc entries causing no prejudice, void judgments, and circumstances transpiring after finality rendering execution unjust and inequitable), none of which existed here. It is of no moment that the opposing party failed to object to the timeliness of the motion for reconsideration; the trial court could not validly entertain a motion filed after the lapse of the appeal period, and not even an appellate court has the power to review a judgment that has acquired finality.

• Annulment of Judgment (Rule 47, Rules of Court) — A remedy in equity so exceptional in nature that it may be availed of only when other remedies are wanting, and only if the judgment, final order, or final resolution sought to be annulled was rendered by a court lacking jurisdiction or through extrinsic fraud. Jurisprudence recognizes a third ground — denial of due process of law. The Court applied this doctrine to grant Charnnel's petition, finding that the RTC's June 28, 2011 Order was rendered in disregard of her right to due process and that the RTC lacked jurisdiction to reverse the 1997 Decision which had already attained finality.

• Due Process in Judicial Proceedings — Due process requires that those with an interest in the subject matter of litigation be notified and afforded an opportunity to defend their interests. Where the denial of the fundamental right of due process is apparent, a decision rendered in disregard of that right is void for lack of jurisdiction. The Court applied this doctrine by finding that Charnnel, a minor and heir of Alphonso, was neither made a party to nor notified of the reconsideration proceedings, and that Jocelyn's Manifestation did not adequately represent Charnnel's distinct interests, thus constituting a denial of due process rendering the RTC's Order void.

• Immutability of Final Judgments — A judgment, once it has attained finality, can never be altered, amended, or modified, even if the alteration, amendment, or modification is meant to correct an erroneous judgment. This principle puts an end to what would otherwise be endless litigation (interest reipublicae ut sit finis litium). The doctrine admits four exceptions: (1) correction of clerical errors; (2) nunc pro tunc entries which cause no prejudice to any party; (3) void judgments; and (4) circumstances transpiring after finality rendering execution unjust and inequitable. The Court applied this doctrine by holding that the 1997 Decision had attained finality by operation of law when the OSG failed to file its motion within the reglementary period, and none of the four exceptions were present.

• Finality by Operation of Law — A judgment becomes final and executory by operation of law upon the lapse of the reglementary period of appeal if no appeal is perfected or no motion for reconsideration or new trial is filed. There is no need for any judicial declaration or performance of an act before finality takes effect. The trial court need not even pronounce the finality of the order. The Court applied this doctrine by holding that the 1997 Decision became final on March 24, 2011, when the OSG's reglementary period expired without a timely filing, and the RTC lost jurisdiction accordingly.

• Standing of Heirs to Assail Void Marriages — Void marriages governed by the New Civil Code can be questioned even after the death of either party. The death of a party does not extinguish the action for declaration of absolute nullity of marriage, as the deceased may have heirs with legal standing to assail the void marriage. The Court applied this doctrine from Niñal vs. Bayadog to uphold Charnnel's legal standing as Alphonso's heir to seek annulment of the RTC's Order.

• "A petition for annulment of judgment is a remedy in equity so exceptional in nature that it may be availed of only when other remedies are wanting, and only if the judgment, final order, or final resolution sought to be annulled was rendered by a court lacking jurisdiction, or through extrinsic fraud." — This passage defines the nature and scope of the remedy of annulment of judgment under Rule 47, establishing the threshold requirements for its availability.

• "Where the denial of the fundamental right of due process is apparent, a decision rendered in disregard of that right is void for lack of jurisdiction." — This formulation articulates the doctrinal link between denial of due process and voidness of judgment for lack of jurisdiction, serving as the ratio decidendi for granting the petition on due process grounds.

• "It is a well-established rule that a judgment, once it has attained finality, can never be altered, amended, or modified, even if the alteration, amendment or modification is to correct an erroneous judgment. This is the principle of immutability of judgments — to put an end to what would be an endless litigation." — This is the canonical statement of the immutability of final judgments doctrine, applied to hold that the RTC lost jurisdiction over the 1997 Decision upon its finality by operation of law.

• "There is no need for any judicial declaration or performance of an act before the finality takes effect. Finality of a judgment becomes a fact upon the lapse of the reglementary period of appeal if no appeal is perfected, or motion for reconsideration or new trial is filed." — This passage defines the doctrine of finality by operation of law, explaining why the 1997 Decision became final without any court pronouncement, simply because the OSG's motion was filed beyond the reglementary period.

• Arcelona vs. Court of Appeals, 345 Phil. 250 (1997) — Cited for the proposition that a decision which is patently void may be set aside on grounds of want of jurisdiction or non-compliance with due process of law, where mere inspection of the assailed judgment is enough to demonstrate its nullity. Followed as supporting authority for the due process ground of annulment.

• Niñal vs. Bayadog, 384 Phil. 661 (2000) — Cited for the rule that void marriages governed by the New Civil Code can be questioned even after the death of either party, and that the death of a party does not extinguish the action for declaration of absolute nullity of marriage because the deceased may have heirs with legal standing. Followed to establish Charnnel's legal standing as Alphonso's heir.

• Spouses Hofer vs. Yu, G.R. No. 231452, July 1, 2020 — Cited for the definition of annulment of judgment as a remedy in equity available only when other remedies are wanting, and only if the judgment was rendered by a court lacking jurisdiction or through extrinsic fraud. Followed as the foundational authority on the nature and grounds of annulment of judgment.

• De Pedro vs. Romasan Development Corp., 748 Phil. 706, 726 (2014) — Cited for the principle that due process requires that those with an interest in the subject matter of litigation be notified and afforded an opportunity to defend their interests, and that courts cannot be expected to deprive persons of their rights to due process while acting within jurisdiction. Followed to support the finding that Charnnel was denied due process.

• Republic vs. Heirs of Gotengco, 824 Phil. 568, 578 (2018) — Cited for the principle of immutability of final judgments and its four recognized exceptions. Followed to hold that the 1997 Decision could no longer be altered once it attained finality, as none of the exceptions applied.

• Ng Ching Ting vs. Philippine Business Bank, Inc., G.R. No. 224972, July 9, 2018 — Cited for the doctrines that a judgment becomes final by operation of law without need for judicial declaration, and that a trial court cannot validly entertain a motion for reconsideration filed after the lapse of the appeal period. Followed to establish that the 1997 Decision attained finality upon the OSG's failure to file a timely motion.

• Section 2, Rule 47, Rules of Court — Provides the grounds for annulment of judgment: extrinsic fraud and lack of jurisdiction. The Court applied this provision and noted that jurisprudence recognizes a third ground — denial of due process of law — under which Charnnel's petition was granted.

Perlas-Bernabe, S.A.J. (Chairperson), Gesmundo, Lazaro-Javier, and Rosario, JJ., concurred.