G.R. No. 157194; June 20, 2006
ANTONIO P. TAN, Petitioner, vs. HON. COURT OF APPEALS, THE HONORABLE WILFREDO D. REYES, Acting Presiding Judge, Regional Trial Court, Branch 31, Manila, THE REGISTER OF DEEDS OF MANILA and DPG DEVELOPMENT & MANAGEMENT CORPORATION, Respondents.

FACTS

Petitioner Antonio P. Tan, a lessee, filed a complaint for the cancellation/annulment of Transfer Certificate of Title (TCT) No. 169146 in the name of private respondent DPG Development & Management Corporation. The trial court initially granted the petition ex parte after declaring DPG in default, ordering the title’s cancellation and the property’s reversion to the government. Upon DPG’s appeal, the Court of Appeals and subsequently the Supreme Court ordered a new trial. During this new proceeding, the trial court dismissed Tan’s complaint, ruling that a Torrens title becomes indefeasible after one year and cannot be collaterally attacked.
Tan’s motion for reconsideration was denied. His counsel failed to file a timely notice of appeal, leading to the finality of the dismissal order. Tan subsequently filed a petition for annulment of judgment before the Court of Appeals, alleging extrinsic fraud and denial of due process due to his former counsel’s negligence in missing the appeal period.

ISSUE

The primary issue is whether the Court of Appeals correctly dismissed the petition for annulment of judgment, thereby affirming the trial court’s orders that had become final and executory due to counsel’s failure to perfect an appeal on time.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the finality of judgments and the limited grounds for annulment of judgment under Rule 47 of the Rules of Court. Perfection of an appeal within the reglementary period is mandatory and jurisdictional. Failure to do so renders the trial court’s decision final and executory, conferring upon the winning party the right to enjoy the finality of the adjudication.
A petition for annulment of judgment is an extraordinary remedy available only on grounds of extrinsic fraud or lack of jurisdiction. The Court found neither ground present. The alleged negligence of counsel in missing the appeal deadline constitutes intrinsic fraud, not the extrinsic fraud required by Rule 47. Extrinsic fraud refers to deceitful conduct outside the trial, such as preventing a party from presenting their case. A client is generally bound by the mistakes and negligence of their counsel. Tan had the opportunity to litigate his claims during the new trial but lost due to a procedural lapse. His failure to avail of ordinary remedies like a timely appeal, without valid justification, precludes relief via annulment of judgment. The Court emphasized that stability of judgments and respect for jurisdictional deadlines are paramount to the judicial system.