**Dr. Fe Lasam v. Philippine National Bank and RTC, Branch 66, San Fernando City, La Union**
### Facts:
1. **Initial Filing:**
– On January 14, 2003, Dr. Fe Lasam (Lasam) filed a complaint for annulment of mortgage against Philippine National Bank (PNB) in the Regional Trial Court (RTC) of San Fernando City, La Union, docketed as Civil Case No. 6778.
2. **Hearing and Dismissal:**
– Lasam was present for a hearing set for initial reception of evidence on February 23, 2010, but her counsel failed to appear. Consequently, the RTC dismissed the case for failure to prosecute and for her counsel’s absence.
3. **First Set of Post-Judgement Filings:**
– Lasam’s former counsel filed an Urgent Manifestation and Motion explaining her missed appearance, but the RTC denied it on April 29, 2010, for being untimely filed.
– Subsequently, her former counsel filed a motion for reconsideration on May 24, 2010, which was denied as a second motion for reconsideration on July 7, 2010.
4. **Appellate Level Attempts:**
– A Petition for Certiorari was filed before the Court of Appeals (CA), docketed as CA-G.R. SP No. 116446, but was dismissed.
– An Urgent Motion for Issuance of a Temporary Restraining Order and/or Preliminary Injunction was filed and similarly dismissed by the CA on November 21, 2012, citing the finality of the RTC’s decisions.
5. **Consultation with New Counsel and Relief Petition:**
– Lasam consulted a different lawyer and subsequently filed a petition for relief from judgment on January 22, 2013, asserting that she was seriously deprived of her rights due to her former counsel’s gross negligence.
### Issues:
1. **Primary Issue:**
– Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction when it dismissed outright Lasam’s petition for relief from judgment and denied her motion for reconsideration.
2. **Timeliness of Petitions:**
– Whether Lasam’s filings fulfilled the strict statutory timelines specified under Rule 38 of the Rules of Court for petitions for relief from judgment.
### Court’s Decision:
1. **Improperly Direct Recourse to the Supreme Court:**
– The Supreme Court dismissed Lasam’s petition for certiorari as it should have been filed with the Court of Appeals due to the principle of hierarchy of courts.
2. **Assessment on the Merits – Timeliness:**
– It was determined that the RTC did not commit grave abuse of discretion. Lasam’s petition for relief was declared filed out of time:
– The petition was filed almost three years after Lasam learned of the RTC’s February 23, 2010 Order.
– The six-month period from the entry of judgment (dated May 3, 2012) had lapsed by the time Lasam filed the petition on January 22, 2013.
### Doctrine:
– **Strict Compliance with Timelines:** Under Section 3, Rule 38 of the Rules of Court, strict compliance with reglementary periods (within 60 days of knowledge and six months from entry of judgment) is jurisdictional and non-negotiable.
– **Hierarchy of Courts:** Direct recourse to the Supreme Court is only justified under special circumstances. The proper route for extraordinary writs against RTC orders is through the Court of Appeals.
### Class Notes:
1. **Rule 38, Rules of Court:**
– “Petition for relief must be filed within: (a) 60 days after petitioner learns of the judgment, final order, or proceeding to be set aside; and (b) six months from entry of such judgment, order, or other proceeding.”
2. **Hierarchy of Courts Doctrine:**
– Respect for the hierarchical structure prevents unnecessary crowding of the Supreme Court’s docket and allocates workload appropriately based on court functions.
### Historical Background:
– This case exemplifies remedial measures and procedural strictness within the Philippine judicial system, highlighting the stringent oversight on timelines and proper appellate channels to avoid overburdening higher courts and ensuring the finality of judicial decisions.
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