GR 205814; (February, 2016) (Digest)
G.R. No. 205814 February 15, 2016
SPOUSES ALFREDO TEANO and VERONICA TEANO, Petitioners, vs. THE MUNICIPALITY OF NAVOTAS, represented by MAYOR TOBIAS REYNALD M. TIANGCO, and MUNICIPAL TREASURER MANUEL T. ENRIQUEZ, Respondents.
FACTS
Petitioners, spouses Teano, filed a complaint before the Regional Trial Court (RTC) to quash warrants of levy issued by the Municipality of Navotas for alleged unpaid real property taxes from 1990 to 2005. They argued the right to collect taxes for 1990-2000 had prescribed, and they were exempt for 2001-2003 as a fire destroyed their machinery, forcing them to lease elsewhere. The RTC initially dismissed the case for lack of jurisdiction, holding petitioners should have first appealed to the Local Board of Assessment Appeals. Upon reconsideration, the RTC reversed itself, finding the right to collect for 1990-2000 had indeed prescribed under the Local Government Code, and ordered respondents to assess and collect only from 2001-2005. This Order became final. Petitioners later filed a Motion to Clarify, questioning the validity of the levied auction and taxes for 2001-2003. The RTC clarified the warrants were not quashed and taxes for 2001-2003 were still due. Dissatisfied, petitioners filed a Petition for Annulment of Judgment with the Court of Appeals (CA).
ISSUE
Whether the Court of Appeals correctly dismissed the Petition for Annulment of Judgment.
RULING
Yes, the Court of Appeals correctly dismissed the petition. A Petition for Annulment of Judgment under Rule 47 of the Rules of Court is an extraordinary remedy available only on grounds of extrinsic fraud or lack of jurisdiction, and only when ordinary remedies like appeal are no longer available through no fault of the petitioner. The RTC’s September 21, 2007 Order, which became final, was issued with jurisdiction as the court had the authority to rule on the prescription of the tax collection right. The subsequent Resolution clarifying the Order did not amend it but merely interpreted its dispositive portion; it was not a new judgment subject to annulment. Petitioners failed to establish any extrinsic fraud or jurisdictional defect. Their recourse was to appeal the clarifying Resolution, not to file an annulment petition. Since the ordinary remedy of appeal was available but not taken, the CA properly dismissed the petition for lack of merit. The Supreme Court affirmed the CA’s dismissal, emphasizing that annulment of judgment cannot substitute for a lost appeal.