GR 150207; (February, 2007) (Digest)
G.R. No. 150207 . February 23, 2007.
VALENTIN P. FRAGINAL, TOMAS P. FRAGINAL and ANGELINA FRAGINAL-QUINO, Petitioners, vs. THE HEIRS OF TORIBIA BELMONTE PARAÑAL, represented by PEDRO PARAÑAL, FELISA PARAÑAL, ABRAHAM PARAÑAL, IRENEA ACABADO and JOSEFA ESTOY, Respondents.
FACTS
The heirs of Toribia Parañal filed a complaint for termination of tenancy and ejectment against Valentin Fraginal, Tomas Fraginal, and Angelina Fraginal-Quino before the Provincial Agrarian Reform Adjudicator (PARAD). The Fraginals, in their Answer, contested the PARAD’s jurisdiction, asserting that the land they cultivated was a 1.1408-hectare public agricultural land under the exclusive jurisdiction of the Department of Environment and Natural Resources, not private land subject to agrarian laws. The PARAD, however, dismissed their evidence as insufficient and ordered their ejectment in a Decision dated October 8, 1998.
Instead of appealing the PARAD Decision to the Department of Agrarian Reform Adjudication Board (DARAB) as provided by law, the Fraginals took no action for over two years. Subsequently, they filed a Petition for Annulment of Judgment directly with the Court of Appeals under Rule 47 of the Rules of Court, arguing the PARAD Decision was void for lack of jurisdiction. The CA dismissed the petition, ruling that a Rule 47 petition for annulment applies only to final judgments of the Regional Trial Courts, not to adjudications of quasi-judicial agencies like the PARAD.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for annulment of judgment on the ground that Rule 47 of the Rules of Court pertains only to judgments of the Regional Trial Courts.
RULING
The Supreme Court affirmed the Court of Appeals and dismissed the petition. The Court held that the remedy of annulment of judgment under Rule 47 of the Rules of Court is an extraordinary remedy available only against final judgments or orders of the Regional Trial Courts in the exercise of their original jurisdiction. It is explicitly not available to assail the judgments, final orders, or resolutions of quasi-judicial agencies like the PARAD/DARAB. The proper remedy against the PARAD’s Decision was a timely appeal to the DARAB, as mandated by the rules governing agrarian proceedings. By failing to avail of this ordinary remedy within the reglementary period, the Fraginals allowed the PARAD Decision to become final and executory.
The Court emphasized the doctrine of finality of judgments, which is fundamental to judicial stability. While certain equitable remedies exist, they must be pursued through the correct procedural avenues. A petition for annulment under Rule 47 is not a substitute for a lost appeal. Since the Fraginals did not utilize the available appeal process to the DARAB, they cannot now collaterally attack the final PARAD Decision via an inapplicable remedy. The CA correctly dismissed the petition for employing a wrong mode of review.