GR 174582; (October, 2012) (Digest)
G.R. No. 174582; October 11, 2012
THE HEIRS OF THE LATE SPOUSES LAURA YADNO and PUGSONG MAT-AN, et al., Petitioners, vs. THE HEIRS OF THE LATE SPOUSES MAURO and ELISA ANCHALES, et al., Respondents.
FACTS
The respondents’ predecessors, the Spouses Anchales, filed a complaint for ownership and possession against several defendants, including the petitioners’ predecessors, the Spouses Mat-an, and Orani Tacay. The defendants were declared in default, and a 1987 decision by the Urdaneta RTC declared the Anchales spouses as absolute owners, ordering the defendants to vacate and pay damages. This decision became final. To satisfy the monetary award, the sheriff levied upon and sold at public auction a property registered under the name of defendant Orani Tacay. The Anchales spouses were the highest bidders, and a new title was eventually issued in their name.
In 1989, the Spouses Mat-an filed a separate action for injunction in the Baguio RTC, arguing the levy and sale were illegal because Orani had died before the Urdaneta RTC rendered its 1987 judgment. They contended her property had passed to her heirs and could not be levied upon. This case was archived but later revived. The Baguio RTC eventually dismissed the injunction case, a decision affirmed by the Court of Appeals. The petitioners elevated the case to the Supreme Court.
ISSUE
Whether the Baguio RTC correctly dismissed the petitioners’ action for injunction, which sought to nullify the execution proceedings and the title derived from the final judgment of the Urdaneta RTC.
RULING
Yes, the Supreme Court affirmed the dismissal. The core legal principle is that a final and executory judgment cannot be attacked collaterally in a separate action. The Urdaneta RTC’s 1987 decision had long become final. The petitioners’ action in the Baguio RTC was a collateral attack on that judgment, as it sought to nullify the execution sale and the resulting title based on alleged defects in the execution proceedings and the underlying judgment itself. The Court held that the proper remedy against a final judgment is a direct attack, such as a petition for relief from judgment or an action for annulment of judgment on grounds of extrinsic fraud or lack of jurisdiction, not an independent action for injunction.
The petitioners’ claim regarding Orani’s death prior to judgment pertained to an alleged error in the proceedings, which did not render the Urdaneta RTC’s judgment void for lack of jurisdiction. Even if the death was not noted, the judgment, being final, could only be challenged through the modes prescribed by law. The Baguio RTC correctly refused to interfere with the final processes of a co-equal court. The execution and the issuance of a new title were legitimate consequences of a final judgment. Therefore, the petition was denied for lack of merit.