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    LASALA Vs NFA

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    Adrian Estember
    Case Digest

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    LASALA Vs NFA

    Uploaded by

    Adrian Estember
    22 views1 page
    Case Digest

    Original Title

    LASALA vs NFA

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    Case Digest

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    22 views1 page

    LASALA Vs NFA

    Uploaded by

    Adrian Estember
    Case Digest

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    LASALA, vs.

    THE NATIONAL FOOD AUTHORITY,

    G.R. No. 171582 August 19, 2015

    Facts: Lasala, provide security guard services to the NFA through his company PSF
    Security Agency. Sometime in 1994, Lasala’s employees who were deployed to the NFA
    filed with the NLRC a complaint for underpayment of wages and nonpayment of other
    monetary benefits. The NLRC ruled for the employees and held Lasala and the NFA
    solidarily liable for the employees’ adjudged monetary award.

    the NFA filed with the RTC, a complaint for sum of money with damages against Lasala.
    the trial court dismissed the NFA’s complaint for failure of its lawyer to present evidenc,
    due to his repeated hearing absences. Although the NFA’s complaint was dismissed,
    Lasala’s counterclaim remained. And eventually was granted.

    the NFA failed to appeal its case to the CA. having lost its chance to appeal, the NFA filed
    with the trial court a petition for relief from judgment grounded on excusable negligence.
    RTC denied the petition thus NFA filed with the CA a petition and an amended petition for
    annulment of judgment on the grounds of lack of jurisdiction and extrinsic fraud.
    The CA granted the petition and annulled the trial court for lack of jurisdiction. Hence
    this petition before the Court.
    Issue: WON the CA erred in annuling RTC decision.
    Ruling: No, the CA did not erred. Annulment of judgment is a recourse equitable in
    character, allowed only in exceptional cases as where there is no available or other
    adequate remedy. It provides only two grounds for annulment of judgment, i.e., extrinsic
    fraud and lack of jurisdiction under Rule 47 of the Rules of Court.

    First, it is only available when the ordinary remedies of new trial, appeal, petition for
    relief, or other appropriate remedies are no longer available through no fault of the
    petitioner.26

    Second, an annulment may only be based on the grounds of extrinsic fraud and lack of
    jurisdiction. Moreover, extrinsic fraud shall not be a valid ground if it was availed of, or
    could have been availed of, in a motion for new trial or petition for relief

    Lastly, if grounded on extrinsic fraud, the petition must be filed within four years from its
    discovery; and if based on lack of jurisdiction, before it is barred by laches or estoppel
    Here, The prior filing of a petition for relief does not per se bar the filing of a petition for
    annulment of judgment. The Court grants NFA’s petition for relief from judgment due to
    extrinsic fraud and lack of jurisdiction of the RTC.

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