G.R. No. 249815 . July 04, 2022.
Gloria A. Chico, Petitioner, vs. Elsie Ciudadano, Respondent.

FACTS

Petitioner Gloria Chico acquired a parcel of land at a tax delinquency sale conducted by the Quezon City Treasurer. The property was originally registered under Rosalita Bengzon. After the redemption period lapsed, a Final Bill of Sale was issued to Chico. She subsequently filed a Petition for Issuance of a New Title before the Regional Trial Court (RTC). The RTC, after due publication and notice, granted the petition, ordered the cancellation of Bengzon’s title, and directed the issuance of a new title in Chico’s name. The decision became final and a new title was issued.
Respondent Elsie Ciudadano later filed a Petition for Annulment of Judgment before the Court of Appeals. She claimed she and her husband had purchased the same property from Bengzon in 1989, as evidenced by a Deed of Absolute Sale annotated on the original title before it was lost in a fire. Ciudadano asserted she was the actual occupant and owner. She argued the RTC judgment was void for lack of jurisdiction over her as an indispensable party who was not impleaded, and that extrinsic fraud attended the proceedings as Chico deliberately excluded her despite knowledge of her claim and occupancy.

ISSUE

Whether the Court of Appeals correctly annulled the RTC’s final and executory judgment in the land registration case.

RULING

No. The Supreme Court reversed the Court of Appeals and reinstated the RTC’s amended decision. The legal logic proceeds from the principles of indefeasibility of a torrens title and the limited grounds for annulment of judgment. A petition for annulment of judgment under Rule 47 of the Rules of Court is an extraordinary remedy confined to the grounds of extrinsic fraud or lack of jurisdiction. Ciudadano failed to establish lack of jurisdiction. Jurisdiction over the subject matter in a petition for issuance of a new title under Sections 75 and 107 of P.D. No. 1529 is conferred by law. The RTC, as a land registration court, properly acquired jurisdiction through Chico’s compliance with statutory publication and notice requirements. The alleged failure to implead Ciudadano did not strip the court of jurisdiction over the res or the subject matter.
Furthermore, Ciudadano did not prove extrinsic fraud, which must be an act committed by the prevailing party outside the trial that prevented the aggrieved party from presenting their case. Chico’s act of not impleading Ciudadano was not extrinsic fraud. Ciudadano, as a buyer under an unregistered deed, was merely a claimant whose interest was not recorded in the Torrens system at the time of the tax sale and the petition. Her remedy was an ordinary civil action to assert her rights, not a collateral attack via annulment of judgment. The Court emphasized that a certificate of title issued pursuant to a final judgment can only be challenged in a direct proceeding, and the annulment of judgment was improperly used to mount such a challenge. The tax delinquency sale and the subsequent judicial confirmation vested a new and valid title in Chico.