G.R. No. 203152 . June 20, 2016.
GEORGIA ROYO ADLAWAN, IN HER OWN BEHALF AND AS SURVIVING SPOUSE OF ALFONSO V. ADLAWAN, PETITIONER, VS. NICETAS I. JOAQUINO, FLORENCIA J. SON, EUSTOLIA J. MATA, BEATRIZ J. SATIRA, TERESITA J. BERMEJO, CORAZON J. COGINA, MARIA J. NOVAL AND VISITACION J. DELA TORRE, RESPONDENTS.

FACTS

The case involves a parcel of land originally owned by Leonora Yngles. Upon her death, the property passed to her children, including Magdalena Joaquino. After Magdalena’s death, her siblings and their heirs executed an Agreement of Partition in 1950. Remedios Cabello, claiming to have acquired the entire lot (Lot No. 7-B) from an heir, successfully petitioned for the reconstitution of its title in 1983 after alleging her title was burned. The reconstituted title was subdivided, and one portion (Lot No. 7-B1) was sold to spouses Robles. In 1987, the respondents, who are co-heirs, filed a complaint to annul the reconstituted title, alleging fraud, and a notice of lis pendens was annotated. However, this complaint was dismissed for failure to prosecute in 1992, and the lis pendens was cancelled. The spouses Robles then sold Lot No. 7-B1 to petitioner Georgia Royo Adlawan and her husband in December 1992. Subsequently, the respondents secured relief from the 1992 dismissal order, reinstated their complaint, and impleaded the Adlawans.

ISSUE

The core issue is whether the Regional Trial Court (RTC) Branch 17 had jurisdiction to grant the respondents’ petition for relief from judgment and subsequently try the annulment case, given that the order granting the reconstitution of title (issued by RTC Branch 14 in 1983) had long become final and executory.

RULING

The Supreme Court ruled that RTC Branch 17 acted without jurisdiction. The legal logic is anchored on the doctrine of finality of judgments and the principle that a court cannot nullify the final judgment of another co-equal court. The 1983 reconstitution order from RTC Branch 14 was a final judgment on the merits regarding the title’s validity. A petition for relief from judgment under Rule 38 is a remedy available only against a final judgment of the same court that rendered it. Here, the respondents sought relief from their own failure to prosecute their annulment case in Branch 17, not from the 1983 reconstitution order of Branch 14. The annulment complaint in Branch 17 was, in substance, a collateral attack on the final reconstitution decree. The Court emphasized that a final judgment can only be challenged via a direct action for its annulment (e.g., on grounds of extrinsic fraud or lack of jurisdiction) or via a petition for relief filed in the very court that rendered it, within a reglementary period. Since the respondents did not timely challenge the 1983 reconstitution order through these proper avenues, it attained immutability. Consequently, Branch 17’s actions, including granting relief and later nullifying the titles, were void for lack of jurisdiction. The Court declared all proceedings in Civil Case No. CEB-6025 null and void, thereby upholding the petitioner’s derivative rights as a buyer.