**Facts:**
1. **Primary Incident (2009)**: Spouses Nestor and Felicidad Victor and Spouses Reynaldo and Gavina Victor (respondents) filed a complaint against Philippine National Bank (PNB) for declaration of nullity of real estate mortgage, extra-judicial foreclosure, and cancellation of the title of a parcel of land.
2. **PNB’s Response**: PNB filed its Answer with a Compulsory Counterclaim.
3. **Respondents’ Motion**: Respondents then filed a Motion for Judgment on the Pleadings.
4. **PNB’s Inaction**: PNB did not respond to the motion, leading to the submission of the complaint for decision.
5. **RTC Decision (April 2011)**: Regional Trial Court (RTC) of Malolos City, Branch 9, declared PNB’s extra-judicial foreclosure proceedings null and void and canceled PNB’s title.
6. **Motion for Reconsideration**: PNB sought an extension of time to file a Motion for Reconsideration which was denied.
7. **Denial of Further Motions**:
– **June 2011**: RTC denied PNB’s Motion to Nullify Proceedings.
– **July 2011**: RTC granted respondents’ motion for the issuance of a writ of execution.
8. **Petition for Relief (July 15, 2011)**: PNB filed a Petition for Relief, claiming deprivation of due process due to the gross negligence of its counsel.
**Procedural Posture:**
– **RTC Denial (August 12, 2011)**: RTC denied the petition for being filed out of the reglementary period.
– **Petition for Certiorari**: PNB filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA).
– **CA Decision (December 21, 2012)**: CA dismissed the petition, citing procedural lapses and no deprivation of due process.
– **Motion for Reconsideration**: PNB’s motion was denied by the CA on April 29, 2013.
– **Supreme Court Appeal**: PNB filed a Petition for Review on Certiorari before the Supreme Court.
**Issues:**
1. **Timeliness of Petition for Relief**: Whether PNB’s Petition for Relief was filed within the prescribed period.
2. **Due Process Deprivation**: Whether the alleged acts of PNB’s counsel deprived it of due process warranting the relaxation of procedural rules.
**Court’s Decision:**
1. **Timeliness of Filing**:
– **Rule 38, Section 3 Compliance**: Petition for Relief must be filed within 60 days from the notice of judgment and not more than six months after such judgment was entered.
– **Compliance Failure**: PNB missed this deadline, having filed the petition on July 15, 2011, well beyond the prescribed period which ended June 27, 2011.
– **Notice to Counsel**: Notice to PNB’s counsel on April 27, 2011, was deemed notice to PNB.
2. **Due Process**:
– **Opportunity for Defence**: PNB had the opportunity to present its case by filing an answer with a compulsory counterclaim to the initial complaint.
– **Counsel’s Role**: Negligence by PNB’s counsel did not equate to a total deprivation of due process.
– **Doctrine Binding of Client to Counsel**: PNB bound by its counsel’s actions, thus no substantive grounds to claim deprivation of due process.
**Doctrine:**
– **Strict Adherence to Procedural Periods**: The twin-period for filing petitions under Rule 38 is jurisdictional and must be strictly complied with.
– **Notice to Counsel Principle**: Notice to a party’s legal counsel constitutes notice to the party.
– **Due Process in Civil Litigation**: Due process is satisfied when a party is given an opportunity to be heard or to present its case.
**Class Notes:**
– **Rule 38 of the Rules of Court**:
– **Section 1**: Relief from judgment due to fraud, accident, mistake, or excusable negligence.
– **Section 3**: 60-day filing requirement from awareness and a six-month limit from judgment entry.
– **Notice to Counsel**: Equates to notice to the client (Taningco v. Fernandez).
– **Doctrine on Counsel’s Negligence**: Client is generally bound by counsel’s actions unless gross negligence precisely deprives due process (Spouses Que v. CA).
– **Due Process**: Mere procedural lapses do not constitute deprivation if the party was afforded reasonable opportunity to present defenses.
**Historical Background:**
– **Judicial Efficiency**: This case highlights the judiciary’s emphasis on procedural efficiency and the finality of litigation.
– **Legal Representation**: Stresses the critical role of competent legal representation in safeguarding clients’ procedural rights and remedies.
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