G.R. No. 228680 SEPTEMBER 17, 2018
SPOUSES FRANCISCO AND DELMA SANCHEZ, represented by HILARIO LOMBOY, Petitioners, vs. ESTHER DIVINAGRACIA VDA. DE AGUILAR, ET AL., THE MUNICIPALITY OF LAKE SEBU, ET AL., Respondents.

FACTS

Petitioners Spouses Sanchez purchased a 600-square-meter portion of a larger lot from Juanito Aguilar in 2000. In 2004, the heirs of Aguilar (respondents) erected a fence on the boundary line between the spouses’ purchased lot and an adjacent 800-square-meter area by Lake Sebu. The spouses filed a forcible entry complaint before the Municipal Circuit Trial Court (MCTC), claiming ownership over the adjacent area as an alluvium that enlarged their property. The heirs countered that the 800-square-meter area was not alluvium but part of their property, which the spouses merely used with tolerance for their fish cage operations.
The MCTC dismissed the complaint, finding the heirs in prior physical possession, evidenced by old trees on the land, and ruling the area was not alluvium as lake water is stagnant. A writ of execution was issued to define the 600-square-meter boundary. Subsequently, the Municipality of Lake Sebu, based on its own survey, notified the spouses that the lakeside area belonged to the heirs, who had priority to use the adjacent waters. An Ad Hoc Committee upheld this. The spouses then filed a Complaint for Annulment of Judgment with the Regional Trial Court (RTC), which ruled in their favor, declaring them owners of the alluvium. The Court of Appeals (CA) reversed the RTC, reinstating the MCTC decision.

ISSUE

Whether the Regional Trial Court erred in taking cognizance of and granting the Complaint for Annulment of Judgment filed by the petitioners.

RULING

The Supreme Court denied the petition and affirmed the CA. The RTC had no jurisdiction over the annulment complaint. A judgment of a Metropolitan Trial Court, Municipal Trial Court, or Municipal Circuit Trial Court can be annulled only on the grounds of extrinsic fraud or lack of jurisdiction, pursuant to Rule 47 of the Rules of Court. The petitioners’ complaint did not allege any extrinsic fraud. Their core argument was that the MCTC decision was void for having been rendered with grave abuse of discretion, constituting an error of judgment.
Errors of judgment, however, are not equivalent to lack of jurisdiction. Jurisdiction is conferred by law and pertains to the court’s authority to hear and decide a case. Once a court has jurisdiction, any error it commits in the exercise of that jurisdiction is merely an error of judgment, correctible not by an annulment proceeding but by appeal. The petitioners’ remedy against the MCTC’s alleged erroneous factual and legal findings was a timely appeal, not an action for annulment. Since they availed of the wrong remedy, the RTC should have dismissed the complaint outright for lack of jurisdiction. The CA correctly reinstated the final and executory MCTC decision.