G.R. No. 171304 October 10, 2007
Heirs of the Late Sps. Timotea L. Palaganas, et al., petitioners, vs. Registry of Deeds – Tarlac City, et al., respondents.

FACTS

The Municipality of Paniqui, Tarlac, built a school, market, and cemetery on an untitled parcel of land in 1910. Original Certificates of Title (OCTs) were subsequently issued in the municipality’s name in 1911 and 1915. In 1993, the Regional Trial Court (RTC) granted the municipality’s petition and ordered the reconstitution of these allegedly lost OCTs into new Transfer Certificates of Title (TCTs). In 2005, petitioners, claiming to be heirs of the land’s original settlers since 1843, filed a Petition for Annulment of Judgment with the Court of Appeals. They alleged their ascendants were unlawfully dispossessed in 1910 and were denied participation in the early 20th-century cadastral proceedings that resulted in the OCTs. They sought to annul the 1993 RTC reconstitution order.
The Court of Appeals dismissed the petition primarily on procedural grounds: it lacked proper verification, did not attach a certified true copy of the assailed RTC decision, and failed to prove it was filed within the four-year prescriptive period from discovery of the alleged fraud. The appellate court further ruled that even if technicalities were set aside, the petition lacked merit. Petitioners failed to substantiate their status as real parties-in-interest, did not allege fraud in the 1993 reconstitution proceedings they sought to annul, and their claim was barred by laches.

ISSUE

Whether the Court of Appeals correctly dismissed the Petition for Annulment of Judgment.

RULING

Yes, the Supreme Court affirmed the dismissal. Procedurally, the petition was correctly dismissed for non-compliance with Rule 47 of the Rules of Court, specifically the requirements for verification, submission of certified true copies, and proof of timeliness. On substantive grounds, the petition was likewise infirm. An action for annulment of judgment based on extrinsic fraud requires that the fraud be committed in the very proceeding assailed, preventing a party from presenting their case. The fraud alleged by petitioners pertained to the cadastral proceedings from 1911-1917, not the 1993 reconstitution case they sought to annul. Furthermore, petitioners failed to establish their standing as legitimate heirs or successors-in-interest to the original occupants, merely relying on surname similarities without proof of filiation. Finally, the claim was barred by laches. The property had been openly, continuously, and exclusively possessed by the municipality in a public capacity for nearly a century, constructing and maintaining public infrastructure. Petitioners’ ancestors and their successors slept on their rights for an inordinate length of time, creating a situation where unsettling the municipality’s title would be inequitable.