GR 153936; (March, 2007) (Digest)
G.R. No. 153936 . March 2, 2007.
ROSARIO M. REYES, Petitioner, vs. ALSONS DEVELOPMENT AND INVESTMENT CORPORATION, REGISTRY OF DEEDS OF DAVAO CITY AND REGIONAL TRIAL COURT, BRANCH 8 (now Br. 15), DAVAO CITY, Respondents.
FACTS
The case originated from an unlawful detainer complaint filed by respondent Alsons against petitioner Rosario M. Reyes in 1980. The MTCC ruled in favor of Alsons, a decision affirmed by the RTC in 1985. The RTC decision became final and executory. Execution ensued, leading to the levy and auction sale of Reyes’s two titled lots in favor of Alsons in 1987. Reyes filed a separate action to cancel the certificate of sale, which was dismissed, and her appeal was ultimately denied by the Supreme Court in 1992. A final certificate of sale was issued in 1989.
In 1993, the RTC ordered the Register of Deeds to issue new titles to Alsons. Reyes then filed an omnibus motion in the original case to vacate that order and set aside the execution, which the RTC denied. She subsequently filed a petition for certiorari with the CA in 1993, challenging the 1985 execution order and related writs. The CA dismissed it in 1995 on the ground of laches, noting an eight-year delay. Reyes later filed an independent action for annulment of judgment with the RTC in 1999, which was also dismissed. The CA sustained this dismissal, prompting the present petition.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of petitioner’s independent action for annulment of judgment.
RULING
No, the Court of Appeals did not err. The Supreme Court denied the petition, emphasizing the doctrines of finality of judgment and laches. The RTC decision in the ejectment case had long become final and executory. Petitioner’s recourse to an independent action for annulment, filed years after the execution proceedings were concluded, constituted an improper collateral attack on a final judgment. The Court ruled that such an action is not a substitute for a lost appeal or a remedy to re-litigate settled matters.
The legal logic is grounded in judicial stability and the rule against forum-shopping. Petitioner had already availed of multiple remedies—an appeal, a separate action to cancel the sale, and a special civil action for certiorari—all of which were resolved against her. Her belated attempt to annul the judgment via a new action, after failing in previous avenues, was correctly barred by laches. The Court held that public policy demands an end to litigation; a final judgment must not be disturbed by subsequent schemes of the losing party. The execution and transfer of title were upheld as valid consequences of a long-final judgment.
