FACTS:

The case involves complaints for ejectment filed by private respondents Primitivo Nepomuceno and Emerenciana Nepomuceno against petitioner's deceased husband, Benjamin Salazar. These complaints were filed with the Court of Agrarian Relations of Malolos, Bulacan in 1970. After several proceedings, a joint decision was rendered in favor of the private respondents. An appeal was filed by the petitioner's deceased husband, challenging the private respondent's compliance with the requirements for personal cultivation and conversion of the landholdings. The Court of Appeals rejected this argument and upheld the trial court's decision.

A year later, the petitioner filed a petition for annulment of judgment, arguing that the trial court lacked jurisdiction over her and the other heirs of her deceased husband due to the absence of a valid substitution of heirs. The Court of Appeals ruled in favor of the validity of the trial court's decision, based solely on the issue of non-jurisdiction resulting from the failure to effectuate a valid substitution of heirs. The petitioner filed a motion for reconsideration, which was denied.

The petitioner then brought the case to the Supreme Court, arguing that a substitution of heirs is necessary for due process. The Supreme Court ruled that although the formal substitution was not necessary in this case because the heirs voluntarily appeared, participated, and presented evidence in defense of the deceased defendant, the substitution of heirs is indeed necessary for due process. The Court of Appeals' resolution denying the motion for reconsideration explained that failure to make the substitution is considered a jurisdictional defect, as the purpose of the rule on substitution of heirs is to comply with due process requirements.

ISSUES:

1. Does the failure of the trial court to effectuate a substitution of heirs before its rendition of judgment render the judgment jurisdictionally infirm?

RULING:

1. The petition is bereft of merit. The Court of Appeals correctly ruled that formal substitution of heirs is not necessary when the heirs themselves voluntarily appeared, participated in the case, and presented evidence in defense of the deceased defendant. Non-compliance with the rule on substitution of heirs does not necessarily result in a jurisdictional defect, but it may violate the right to due process of those substantially affected by the decision. In this case, the heirs of the deceased defendant actively participated in the proceedings, negating any violation of their rights to due process.

PRINCIPLES:

• The need for substitution of heirs is based on the right to due process accruing to every party in any proceeding. The requirement for substitution of heirs is to ensure that those who are substantially affected by the decision are given their day in court.

• Failure to effectuate a valid substitution of heirs may render a judgment null and void if the court acquires no jurisdiction over the persons of the legal representatives or heirs. However, if the heirs themselves voluntarily appear, participate in the case, and defend the deceased defendant, formal substitution of heirs may not be necessary.