G.R. No. L-17322. June 30, 1962. IGNACIO SANTIAGO, plaintiff-appellant, vs. EULOGIA CENIZA, FRANCISCA TABLADA and ERIBERTO UNSON, the latter in his capacity as City and Provincial Sheriff of Davao, defendants-appellees.
FACTS

Plaintiff-appellant Ignacio Santiago was the defendant in two consolidated civil cases for unlawful detainer and collection of rentals filed by defendants-appellees Eulogio Ceniza and Francisco Tablada. After trial, the Court of First Instance of Davao rendered a decision in February 1951, which, among other things, ordered Santiago to pay monthly land rentals to Ceniza and Tablada. This judgment was affirmed by the Court of Appeals on July 30, 1955, and became final and executory. Subsequently, the case was remanded to the trial court for execution.
On January 8, 1957, Santiago filed a separate action for annulment of judgment with injunction against Ceniza, Tablada, and the Sheriff of Davao. He alleged that the affirmed decision, insofar as it required him to pay land rentals, was contrary to law, specifically the Public Land Act. The trial court dismissed this complaint, ruling that the action sought to annul a final judgment on matters within the court’s jurisdiction, and that any error should have been corrected on appeal, not through annulment.

ISSUE

Whether the trial court correctly dismissed the action for annulment of the final and executory judgment.

RULING

Yes, the trial court correctly dismissed the action. The Supreme Court affirmed the dismissal, holding that an action for annulment of a final judgment is not a proper remedy under the circumstances alleged by Santiago. The Court clarified that a final and executory judgment may only be annulled on specific grounds: (1) if the judgment is void for lack of jurisdiction or due process of law, or (2) if it was obtained by fraud. Santiago’s complaint contained no allegation of fraud. His sole contention was that the decision was contrary to law, a matter that had been definitively passed upon and settled by both the trial court and the Court of Appeals in the original proceedings. Public policy strongly favors the stability and finality of judicial decisions. Allowing a party to relitigate issues already conclusively resolved under the guise of annulment would undermine this principle. Since the judgment was rendered by a court with proper jurisdiction and the alleged error was one of law or fact already adjudicated, the remedy of annulment was unjustified. The proper recourse for such an error was a timely appeal, not a collateral attack after finality.