G.R. No. L-48190 August 31, 1987
Luisa Brillante Ocampo, et al., petitioners, vs. Andres Arboleda, et al., respondents.

FACTS

Private respondents, the Arboledas, filed an action for quieting of title, ejectment, and damages (Civil Case No. 5013) against petitioners, the Ocampos and Alejandro Brillante. The Arboledas claimed absolute ownership of a parcel of land by virtue of a transfer certificate of title and an extra-judicial partition and sale, asserting that petitioners, who were their relatives, merely occupied the land by tolerance. The trial court rendered judgment in favor of the Arboledas, declaring them the lawful owners and ordering petitioners to vacate and pay damages. Petitioners, despite notifications, failed to appear at the pre-trial conferences and were declared in default. Their subsequent motion for reconsideration and petition for relief from judgment were denied for being filed out of time and for merely rehashing their defenses.
Subsequently, petitioners filed a separate action for annulment of judgment (Civil Case No. 5643), reiterating their claim of being co-heirs to the property and alleging fraud and lack of due process in the earlier case. The trial court dismissed this annulment case. Petitioners then elevated the matter to the Supreme Court via the instant petition, arguing that the default judgment in the first case was void.

ISSUE

Whether the trial court committed reversible error in dismissing the action for annulment of judgment (Civil Case No. 5643) and in upholding the final and executory decision in the ejectment case (Civil Case No. 5013).

RULING

The Supreme Court dismissed the petition and affirmed the dismissal of the annulment case. The legal logic is anchored on the principles of finality of judgment, res judicata, and the proper grounds for annulment. First, the Court found that due process was not denied to petitioners in Civil Case No. 5013. They were duly notified of all proceedings, including the pre-trial conferences. Their failure to appear and present their defense was a matter of their own choice, not a deprivation of their right to be heard. A judgment rendered after a party is declared in default for non-appearance, despite notice, is valid.
Second, the action for annulment of judgment was correctly dismissed as it failed to allege any valid ground for annulment under the rules. Petitioners did not sufficiently prove extrinsic fraud, which must be a fraud committed outside the trial that prevented them from presenting their case. Their allegations pertained to matters that could and should have been raised during the original proceedings. Furthermore, the Court found all elements of res judicata present: a final judgment on the merits rendered by a court with jurisdiction, identity of parties, subject matter, and causes of action between the first and second cases. The finality of the decision in the ejectment case barred its re-litigation. Petitioners’ remedy was a timely appeal from the original decision, which they failed to pursue, allowing the judgment to become final and executory.