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 involves a long-standing property dispute over Lot 196. In Civil Case No. 11085, the Court of First Instance declared petitioners Ramos, Millado, and Erie as co-owners of the western half, and respondents, the Medinas, as co-owners of the eastern half. This 1977 decision was affirmed by the Intermediate Appellate Court in 1985 and became final in 1986. Subsequently, in Civil Case No. 402, the RTC granted the Medinas’ motion for partial judgment, ordering the revival and enforcement of the final 1985 appellate decision. It declared petitioners’ titles null and void and directed reconveyance of the eastern half to the Medinas. This 1996 RTC Order was affirmed by the CA and the Supreme Court.
In December 1999, petitioners filed a petition for annulment of judgment under Rule 47 before the CA, seeking to annul both the 1977/1985 decision and the 1996 RTC Order, alleging extrinsic fraud. The CA dismissed the petition for failure to state the material dates to prove timeliness and for lack of an affidavit of merit. Petitioners elevated the case, arguing that a void judgment can be attacked anytime, negating the need to state material dates.

ISSUE

The primary issue is whether a petition for annulment of judgment under Rule 47 must comply with the requirement to state material dates to demonstrate timeliness of filing.

RULING

The Supreme Court denied the petition, upholding the CA’s dismissal. The Court clarified that an action for annulment of judgment is an exceptional, equitable remedy limited to the grounds of extrinsic fraud or lack of jurisdiction. It is not a substitute for lost appeal or review. Contrary to petitioners’ claim, such a petition does not presuppose a void ab initio judgment attackable at any time. Rule 47, Section 3 explicitly prescribes a four-year period to file an action based on extrinsic fraud, counted from the discovery of the fraud. Therefore, stating material dates in the petition is imperative to allow the court to determine if the action was filed within this reglementary period. Failure to do so warrants dismissal. The Court further found petitioners’ allegations of extrinsic fraud unmeritorious, as the core issue of ownership had been conclusively settled in the final and executory 1985 decision. The subsequent proceeding in Civil Case No. 402 merely enforced that final judgment. Thus, the petition for annulment was correctly dismissed for procedural infirmity and lack of substantive merit.