View full case

ABUBAKAR A. AFDAL v. ROMEO CARLOS

FACTS:

This is a petition for review of the Orders of the Regional Trial Court (RTC) in a case involving a complaint for unlawful detainer and damages filed by the respondent against the petitioners. The complaint alleged that the petitioners and others were occupying a parcel of land owned by the respondent, despite the respondent claiming to have bought the property from petitioner Abubakar. The Lupon ng Tagapamayapa issued a "certificate to file action" after the petitioners ignored the notice, and the respondent subsequently filed the complaint before the Municipal Trial Court (MTC).

Attempts to serve the summons and complaint on the petitioners were made, but they failed to file an answer. The MTC then ruled in favor of the respondent, ordering the petitioners to vacate the property and pay rental arrears and attorney's fees. The petitioners filed a petition for relief from judgment with the MTC, which was later withdrawn. They then filed the petition for relief before the RTC, claiming to be the lawful owners of the property and stating that they had never sold it to the respondent. The RTC dismissed the petition, citing lack of jurisdiction, and denied the petitioners' motion for reconsideration.

The petitioners now argue that the RTC erred in dismissing their petition for relief from judgment.

ISSUES:

  1. Whether the RTC erred in dismissing the petitioners' petition for relief from judgment.

RULING:

  1. The RTC did not err in dismissing the petition for relief from judgment.

    • A petition for relief from judgment in forcible entry and unlawful detainer cases is a prohibited pleading under both the Rules of Court and the Revised Rule on Summary Procedure.

    • The RTC has no jurisdiction to entertain petitions for relief from judgments of the MTC.

    • The correct remedy for petitioners is to file a petition for certiorari with the RTC under Rule 65 of the Rules of Court on the ground of lack of jurisdiction of the MTC over their person due to absence of summons.

    • The Supreme Court treated petitioners' petition for relief from judgment as a petition for certiorari before the RTC.

PRINCIPLES:

  1. Prohibited Pleadings and Motions

    • Petitions for relief from judgment in forcible entry and unlawful detainer cases are prohibited pleadings.

  2. Jurisdiction Over Person

    • Jurisdiction over the person of the defendant is necessary for the court to validly try and decide a case.

    • Jurisdiction can be acquired either by valid service of summons or voluntary appearance in court.

    • For substituted service of summons to be valid, the impossibility of personal service must be clearly explained and justified in the proof of service.

  3. Validity and Finality of Judgment

    • A judgment issued by a court without jurisdiction over the person of the defendant is null and void and does not attain finality.