GR 113796; (December, 2000) (Digest)
G.R. No. 113796; December 14, 2000
CRESENCIANO C. BOBIS, et al., petitioners, vs. COURT OF APPEALS, HON. GERONIMO R. SAN JOSE, JR., et al., and the HEIRS OF JULIAN BRITANICO, respondents.
FACTS
The case originated from a complaint for quieting of title filed by Julian Britanico (predecessor of private respondents) in 1977 concerning a parcel of land in Tabaco, Albay. The named defendants repeatedly failed to appear, with two eventually disclaiming any interest. Consequently, the trial court allowed Britanico to present evidence ex parte. He established his claim based on a 1973 deed of sale from the Breva siblings. On October 19, 1989, the court rendered a decision declaring Britanico the absolute owner. After his death, his heirs moved for execution and, later, a writ of demolition against eight houses on the property.
The petitioners, who were not parties to the original case, opposed the demolition. They claimed ownership of the houses and the lots, having acquired them through separate deeds from members of the Breva family between 1966 and 1981. They argued the decision in Civil Case No. T-417 could not bind them as they were not impleaded, and alleged that the sale to Britanico was spurious. The trial court initially denied the demolition but later granted it upon reconsideration.
ISSUE
Whether the decision in Civil Case No. T-417 can be annulled on the ground of extrinsic fraud committed by the prevailing party.
RULING
No. The Supreme Court affirmed the Court of Appeals’ dismissal of the petition for annulment of judgment. The Court clarified that for a final judgment to be annulled based on fraud, the fraud must be extrinsic or collateral. Extrinsic fraud refers to a fraudulent act committed outside the trial which prevents a party from having a fair submission of the controversy, such as being kept from attending the trial or from presenting one’s case. Intrinsic fraud, which pertains to matters that were or could have been litigated within the trial, is not a valid ground.
The Court found the petitioners’ allegations constituted intrinsic fraud. Their claim—that the sale to Britanico was fraudulent and that they had superior titles—involved issues directly related to the merits of the ownership dispute. These were matters that could and should have been raised during the trial of Civil Case No. T-417 had the petitioners been properly impleaded or had the original defendants diligently participated. The failure to implicate the petitioners in the original suit did not, by itself, amount to extrinsic fraud perpetrated by Britanico. There was no showing of any deliberate, external scheme designed to prevent the petitioners from participating in the litigation. Consequently, the trial court’s decision had attained finality and could not be annulled. The petition was denied for lack of merit.