G.R. No. 144273. October 20, 2005.
RODOLFO RAMOS, EMMA R. MILLADO, and NORMA R. ERIE, Petitioners, vs. HON. JUDGE ALFONSO V. COMBONG, JR., REGIONAL TRIAL COURT, NEGROS OCCIDENTAL, LA CARLOTA CITY, TEODORO MEDINA, JESUS MEDINA TERESITA MEDINA and THE REGISTER OF DEEDS OF LA CARLOTA CITY, Respondents.

FACTS

This case originated from a dispute over Lot 196. In a 1977 decision in Civil Case No. 11085, the then Court of First Instance declared petitioners and private respondents as co-owners pro indiviso of the lot, each entitled to one-half. This decision was affirmed by the Intermediate Appellate Court in 1985 and became final in 1986. Subsequently, in Civil Case No. 402, the Regional Trial Court, upon private respondents’ motion, ordered the revival and enforcement of the final 1985 judgment. It declared petitioners’ titles null and void and ordered reconveyance of one-half of the lot to respondents. This 1996 Order was affirmed by the Court of Appeals, and a petition to the Supreme Court (G.R. No. 136376) was denied.
Petitioners then filed a separate petition with the Court of Appeals seeking the annulment of the judgments in both Civil Case Nos. 11085 and 402, primarily alleging extrinsic fraud. The CA dismissed this petition for failure to state the material dates to prove timeliness and for non-attachment of an affidavit of merit. Petitioners elevated the case to the Supreme Court.

ISSUE

The core issues are: (1) whether a petition for annulment of judgment under Rule 47 must state material dates to show timeliness; and (2) whether the assailed judgments can be annulled based on extrinsic fraud.

RULING

The Supreme Court denied the petition, affirming the CA’s dismissal. On the first issue, the Court held that a petition for annulment of judgment must strictly comply with Rule 47, Section 3, which requires that an action based on extrinsic fraud be filed within four years from its discovery. Stating material dates is therefore essential to demonstrate that the petition was filed within this prescriptive period. Annulment is an exceptional, equitable remedy that does not suspend the ordinary rules of prescription; it presupposes a valid but voidable judgment, not one void ab initio which can be attacked anytime.
On the second issue, the Court found no merit in the claim of extrinsic fraud. The fraud alleged pertained to the merits of the original ownership dispute in Civil Case No. 11085, specifically questions regarding the respondents’ predecessor’s title. The Court emphasized that these were issues already fully litigated and conclusively resolved by the final 1985 judgment. Extrinsic fraud refers to deceitful conduct outside the trial, like preventing a party from presenting their case, not to matters already adjudicated. For Civil Case No. 402, which was merely for revival of the final judgment, the trial court correctly limited itself to enforcing the prior final ruling. Petitioners’ failure to timely challenge the 1985 judgment and their attempt to relitigate settled issues through an annulment petition, filed well beyond the four-year period from the discovery of the alleged fraud, warranted dismissal.