G.R. No. 147082 ; January 28, 2008
HEIRS OF MAURA SO, namely, YAN LAM LIM, JIMMY SO LIM, and FERDINAND SO LIM, petitioners, vs. LUCILA JOMOC OBLIOSCA, ELVIRA JOMOC GARDINAB, and HEIRS OF ABUNDIA JOMOC BALALA, namely, ROSITA BALALA ACENAS, EVANGELINE BALALA BAACLO, OLIVER JOMOC BALALA, and PERLA BALALA CONDESA, respondents.

FACTS

The dispute originated from a sale of a parcel of land owned by the heirs of Pantaleon Jomoc to Maura So. Respondents Lucila, Abundia, and Elvira Jomoc were among the heirs but did not sign the initial deed. Maura So filed a complaint for specific performance against the other heirs, which culminated in a final and executory Supreme Court decision in her favor. Notably, respondents were not formally impleaded as parties in that specific performance case. When Maura So moved for execution, respondents opposed, arguing they were not bound by the judgment. The trial court granted execution, and respondents’ subsequent petitions for certiorari and review were denied by the CA and Supreme Court (G.R. No. 110661), which held they were bound due to their awareness of the case and failure to intervene.
Subsequently, respondents filed a separate complaint for legal redemption against Maura So’s heirs. The RTC dismissed this, ruling it was barred by res judicata due to the prior final judgment. Respondents then filed a petition for annulment of judgment with the CA, challenging the RTC’s orders in the legal redemption case. The CA dismissed the annulment petition, holding it was an improper remedy since respondents had already availed of, and lost, an appeal via a petition for review on certiorari (Rule 45) to the Supreme Court regarding the same RTC orders.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for annulment of judgment on the ground that a petition for review on certiorari under Rule 45 had already been filed and denied.

RULING

The Supreme Court REVERSED the Court of Appeals and GRANTED the petition. The CA incorrectly applied the rule that an annulment of judgment is unavailable if an appeal via Rule 45 was taken. The legal logic is that the remedies of appeal (Rule 45) and annulment of judgment are distinct and based on different grounds. An appeal attacks the judgment’s factual or legal correctness, while an annulment of judgment assails the judgment’s validity due to extrinsic fraud or lack of jurisdiction. The fact that respondents previously filed a Rule 45 petition questioning the RTC’s dismissal of their legal redemption case on res judicata grounds did not foreclose their right to later file an annulment case. The annulment petition raised the distinct ground that the RTC’s orders in the redemption case were void for having been issued with grave abuse of discretion, essentially amounting to lack of jurisdiction. Since the two remedies address different juridical issues, the pursuit of one does not bar the other. The Court emphasized that technicalities should not prevail if they sacrifice substantial justice, especially when the annulment action raises a potentially meritorious claim regarding a void judgment.