G.R. No. 80486 November 15, 1989
SPOUSES SALVADOR AND IGNACIA ESMILLA, petitioners, vs. FEDERICO ALVAREZ, JESUS SAMORTIN, RAYMUNDO REMOLLINO, AND THE REGIONAL TRIAL COURT OF QUEZON CITY, BRANCH 102, respondents.

FACTS

The petitioners, spouses Esmilla, obtained a favorable judgment in ejectment cases against the private respondents from the Metropolitan Trial Court (MTC) of Quezon City. The private respondents received the MTC decision on January 19, 1987, but filed their notice of appeal only on February 5, 1987, which was two days beyond the 15-day reglementary period. Consequently, the MTC granted the petitioners’ motion for execution. The private respondents then filed a petition for certiorari with the Supreme Court (G.R. Nos. 77702-05), which was dismissed, with the Court ruling that certiorari cannot substitute for a lost appeal. The dismissal became final and was entered in June 1987.
Subsequently, the private respondents filed an action for annulment of the MTC judgment with the Regional Trial Court (RTC), docketed as Civil Case No. Q-51057. They alleged that the properties they occupied were covered by Presidential Decree No. 1517 (the Urban Land Reform Act), arguing that this law barred their ejectment and deprived the MTC of jurisdiction. The RTC granted their prayer for a preliminary injunction, enjoining the execution of the MTC judgment. The petitioners moved to dismiss the complaint on the ground of res judicata, but the RTC denied their motion, prompting the instant petition for certiorari.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in taking cognizance of the action for annulment of judgment and in issuing a writ of preliminary injunction against the execution of a final and executory MTC judgment in the ejectment cases.

RULING

The Supreme Court granted the petition, ruling that the RTC committed grave abuse of discretion. The legal logic is anchored on the finality of judgments and the principle that one cannot do indirectly what is prohibited directly. The MTC judgment in the ejectment cases had become final and executory due to the private respondents’ failure to perfect a timely appeal. This finality was affirmed by the Supreme Court’s prior resolution in G.R. Nos. 77702-05, which dismissed their certiorari petition. An action for annulment of judgment is an extraordinary remedy, permissible only on grounds of extrinsic fraud, lack of jurisdiction, or if the judgment is void on its face. The private respondents failed to substantiate any such ground.
Their claim that PD 1517 ousted the MTC of jurisdiction is without merit. The Court clarified that while PD 1517 grants legitimate tenants of at least ten years a right of first refusal to purchase the land, this protection is triggered only when the landowner intends to sell the property to a third party. It does not grant immunity from ejectment for causes like non-payment of rent, nor does it strip the MTC of its jurisdiction over unlawful detainer cases. The private respondents’ action was merely an indirect attempt to relitigate issues already settled by a final judgment, constituting a blatant violation of the doctrine of res judicata. Therefore, the RTC had no legal basis to entertain the annulment case or to enjoin the execution of the final MTC decision. The Supreme Court ordered the dismissal of Civil Case No. Q-51057 and made permanent the temporary restraining order it had issued.