G.R. No. 76366 July 3, 1990
SPOUSES DONATO RAMIREZ AND MARIA RAMIREZ, petitioners, vs. HON. COURT OF APPEALS, HON. REGIONAL TRIAL COURT OF PINAMALAYAN, ORIENTAL MINDORO AND IGMEDIO REYES, respondents.

FACTS

The land in question is a strip originally donated to the government in 1923 by the predecessor of private respondent Igmedio Reyes for a road. The government failed to construct the road, leading to a revocation of the donation in 1959. In 1960, the government appropriated a different strip from Reyes’s property and built the Malitbog-Naksib Narra Road there. Subsequently, the government and Reyes executed Road Right of Way Agreements, effectively exchanging the originally donated strip for the newly constructed road strip. When Reyes sought to possess the exchanged area, he found petitioners Donato and Maria Ramirez in actual possession and cultivation. Reyes filed a recovery suit (Civil Case No. R-184). During pre-trial, petitioners manifested they were no longer interested in the land and were dropped as parties. A 1976 decision in that case became final and was executed.

ISSUE

The core issue is whether the petitioners can successfully challenge the validity of the judgment in a subsequent recovery suit (Civil Case No. R-540) filed against them by Reyes, and the subsequent execution proceedings, including an auction sale of their properties.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic proceeds on several grounds. First, petitioners were validly declared in default in Civil Case No. R-540 for failure to furnish a copy of their answer to Reyes and for non-appearance at pre-trial. They did not move to lift the default order, and their subsequent failure to file an appellant’s brief led to the dismissal of their appeal, rendering the judgment final and executory. A final judgment can only be attacked on grounds of lack of jurisdiction or extrinsic fraud, which petitioners failed to substantiate. Second, petitioners lack legal standing to challenge the Road Right of Way Agreements, as they were not parties or beneficiaries to those contracts. Their claim of acting in public interest is belied by their evident personal agricultural use of the land. Third, petitioners are barred from impugning the auction sale conducted without republication after a postponement. The initial sale notice was properly published. The postponement was granted due to petitioners’ own motion for injunctive relief. They did not raise the republication issue in their annulment suit, are estopped by their subsequent litigation conduct, and challenged the sale only after the redemption period lapsed and a final deed of sale was issued. Thus, the Court upheld the finality of the judgment and the validity of the execution proceedings.