Scribd
Upload
721 views

Sandejas Vs Robles

This case involves an appeal of a judgment from a trial court in Iloilo during the Japanese occupation. The appellants contend that the trial court lacked jurisdiction to render the original judgment. Specifically, (1) the trial court no longer had authority since major portions of the territory were overrun, and (2) the appellants were deprived of their day in court. However, the Supreme Court ruled that the original action was an in personam action against the appellants personally, not a quasi in rem action against the property. As such, the trial court had jurisdiction over the appellants who had submitted to the court's jurisdiction. The absence from trial was due to the appellants' own fault, not a deprivation of their

Uploaded by

Ronald Alasa-as Atig
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
721 views

Sandejas Vs Robles

This case involves an appeal of a judgment from a trial court in Iloilo during the Japanese occupation. The appellants contend that the trial court lacked jurisdiction to render the original judgment. Specifically, (1) the trial court no longer had authority since major portions of the territory were overrun, and (2) the appellants were deprived of their day in court. However, the Supreme Court ruled that the original action was an in personam action against the appellants personally, not a quasi in rem action against the property. As such, the trial court had jurisdiction over the appellants who had submitted to the court's jurisdiction. The absence from trial was due to the appellants' own fault, not a deprivation of their

Uploaded by

Ronald Alasa-as Atig
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Sandejas vs Robles 81 Phil 421

FACTS:
This is an appeal from an order of CFI of Iloilo dismissing the plaintiff’s action upon motion of defendant
on the ground that it is barred from prior judgment.

The appellants contend that CA erred in upholding the validity of judgment of the CFI during the
Japanese occupation because:
1. The said court has no jurisdiction to try the case, much less to render the decision in question
2. That granting for the sake of argument that the puppet CFI of Iloilo has no jurisdiction, yet such
decision was rendered after having deprived plaintiff of his day in court and is therefore in
violation of the due process clause of the Constitution.

This is in connection with the sale of the 3 parcels of land located in the Municipality of Passi, province of
Iloilo which was resolve by the CFI of Iloilo. The appellants submitted themselves to the jurisdiction of
the CFI by filing their answers to the complaint. They were notified of the date set for the hearing of the
action, but when the case was called, their attorney asked and obtained permission from the court to
withdraw his appearance as attorney on the ground that it was difficult to communicate with his clients.
The hearing was postponed and set on the afternoon of the same day, but appellants did not appear and
judgment was rendered, declaring the resolution of the contract between parties and ordering the
appellees to return to the appellants the sum of P5,723.60, receive by the former from the latter as
payment on account of the sum of P35,000 agreed upon as purchase price.

By then, the puppet Republic of the Philippines could no longer assert its authority over major portions
of the territory since it was already overrun by the Panay guerilla forces since the middle of September
1944. The CFI of Iloilo has no jurisdiction over the res or the property because the action was quasi in
rem, and therefore the said judgment is null and void.

ISSUE:
WON the action is an action in quasi in rem (action against the whole world).

RULING:

No. The action constituted by the appellant’s is in personam and not quasi in rem.

An action in personam has for its object a judgment against the person, as distinguished from a
judgment against the property, to determine its status. It is a proceeding to enforce personal rights and
obligations brought against the person and based on jurisdiction of the person, although it may involve
his right to, of the exercise of ownership of, specific property, or seek to compel him to control or dispose
of it in accordance with the mandate of the court.

The action quasi in rem differs from the true action in rem in the circumstances that in the former, an
individual is named as defendant, and the purpose of the proceeding is to subject his interest therein to
the obligation or lien burdening the property. All proceedings having for their sole object the sale or
other disposition of the property of the defendant, whether by attachment, foreclosure, or other form of
remedy, are in a general way thus designated. The judgment entered in these proceedings is conclusive
only between the parties.
The absence from trial of the appellants was due to their own fault. Appellants’ contention that they
were deprived of their day in court is untenable. The appeal was dismissed.

You might also like