Ilasco Jr. vs.

Court of Appeals, 228 SCRA 413

Topic: Section 6, Rule 1

Facts:

Private respondent Rodillo filed a civil case before the CFI wishing to annul the donation of  half of the
land that she and his uncle Cipriano inherited from Asuncion. Cipriano falsely stated that he is the sole
heir of the land and donated half of it to the petitioner Ilasco spouses to the prejudice of Rodillo who is
also an heir.

The summons have not been served as the Ilaso spouses were based in the US. Because of this, Rodillo
filed a Motion for Leave to Archive Case which was approved. Rodillo then wished to revive the case
which was again granted but as no further action was taken by Rodillo, the CFI granted the Ilaso spouses’
Motion to Dismiss and Cancellation of Notice of Lis Pendens.

Rodillo filed another case in the RTC against the Ilasco spouses which was dismissed on the grounds of
res judicata. At the CA, the decision was reversed stating that res judicata is inapplicable due to
environmental circumstances: the dependence of Rodillo to her counsel and the failure to serve the
summons. The Ilaso spouses appealed stating the principle of res judicata.

Issue: WON the CA erred in reversing the RTC’s decision on the ground of environmental circumstances.

Held:

Yes, the CA erred in reversing the RTC’s decision.

The issue was whether the Order of the CFI operated as res judicata to the case filed before the RTC.
What the CA resolved was the question of whether the CFI erred in dismissing the case without stating
that the dismissal was "without prejudice." Invoking the rule that justice should not be sacrificed to
technicality, the CA set aside the Order of the dismissal.

According to Rule 1, Section 6 of the 1997 Rules of Court, 

Section 6.. Construction. — These Rules shall be liberally construed in order to promote their objective of
securing a just, speedy and inexpensive disposition of every action and proceeding. 

However, the Court held that before procedural rules can be relaxed to give way to substantive justice, it
is implicit that such liberality be applied in a proper case.

Private respondent is bound by the negligence and mistakes in procedural matters of her counsel.

It is a principle of public policy that at the risk of occasional errors, judgments of court should become final
at some definite time fixed by law. The very object of which the courts were constituted was to put an end
to controversies.