G.R. No. L-16252; September 29, 1964
ROSARIO MAS, plaintiff-appellant, vs. ELISA DUMARA-OG and BENIGNO ABALAJON, defendants-appellees.

FACTS

The defendants, Elisa Dumara-og and Benigno Abalajon, filed a money claim against Rosario Mas in the Court of First Instance (CFI) of Iloilo. Based on a confession of judgment signed by Mas, a decision was rendered against her. This judgment became final, leading to the levy and execution sale of Mas’s properties in Antique to the defendants. A final deed of sale was executed, and a writ of possession placed the defendants in possession of the property.
Subsequently, Rosario Mas filed a complaint in the CFI of Antique seeking to annul the Iloilo court’s judgment. She alleged that her signature on the confession of judgment was obtained through fraud and deceit. The defendants moved to dismiss the complaint, arguing that the CFI of Antique lacked jurisdiction over the subject matter. They contended that an action to annul a judgment must be filed in the same court that rendered it. The CFI of Antique granted the motion and dismissed the complaint, prompting Mas’s appeal.

ISSUE

The primary issue is whether the Court of First Instance of Antique has the authority to entertain an action to annul the final and executory judgment rendered by the Court of First Instance of Iloilo.

RULING

The Supreme Court affirmed the dismissal, holding that the CFI of Antique correctly declined jurisdiction. The legal logic rests on the fundamental principle of judicial stability and the coordinate and co-equal nature of courts of first instance. The CFI of Iloilo and the CFI of Antique, while geographically separate, are both branches of the same judicial district (the 11th Judicial District) and are courts of concurrent and coordinate jurisdiction.
Pursuant to the doctrine of judicial stability, a court of coordinate jurisdiction cannot interfere with, modify, or annul the final judgment of another court of equal rank. The power to open, modify, or vacate a judgment is restricted to the very court that rendered it. This rule prevents conflict of authority and ensures orderly administration of justice. The allegation of fraud in obtaining the judgment does not alter this principle; such fraud is considered a matter that primarily affects the court whose processes were allegedly vitiated, and thus relief must be sought from that same court.
The appellant’s arguments regarding jurisdiction under Republic Act No. 296 and venue for personal actions were found misplaced. While Courts of First Instance generally have jurisdiction over such actions, the specific remedy of annulment of a judgment from a co-equal court must be pursued in the rendering court. The Court also rejected the argument that because the action affected title to land in Antique, venue was proper there. It ruled that the action to recover the land was dependent on first obtaining annulment of the Iloilo judgment, which is a prerequisite that must be secured in Iloilo. Consequently, Mas’s proper remedy was to seek annulment in the CFI of Iloilo, not in Antique.