GR L 52092; (April, 1986) (Digest)
G.R. No. L-52092. April 8, 1986
Leonardo Avedaña and Purificacion Timbang, Plaintiffs-Appellants, vs. Manolito Bautista and the Court of First Instance of Pasay City, Branch XXIX, Defendants-Appellees.
FACTS
Plaintiffs-appellants Leonardo Avedaña and Purificacion Timbang filed an action to annul a prior judgment in Civil Case No. 3782-P, which was an ejectment suit filed against them by defendant-appellee Manolito Bautista for recovery of possession of a parcel of land. In that prior case, the plaintiffs claimed to be lessees under a contract executed between their mother, Fausta Timbang, and Manuel Bautista, father of Manolito. The Court of First Instance ruled in favor of Manolito Bautista, a decision affirmed by the Court of Appeals. The plaintiffs then filed the present annulment case, alleging the trial court in the prior case acted in evident bad faith, fraudulently rendered a decision despite knowing it lacked jurisdiction, and disregarded the testimony of Manuel Bautista. They further argued Manolito Bautista, as heir, was bound by the lease contract executed by his father.
Defendant Bautista moved to dismiss the complaint, contending the action was barred by prior judgment and was merely a dilatory tactic to thwart the execution of a final decision. The Court of First Instance granted the motion to dismiss. Plaintiffs appealed to the Court of Appeals, which certified the appeal to the Supreme Court as involving purely questions of law.
ISSUE
Whether the complaint for annulment of judgment sufficiently alleged a valid cause of action, specifically on the grounds of extrinsic fraud or lack of jurisdiction.
RULING
The Supreme Court affirmed the dismissal of the complaint, finding no merit in the appeal. The Court held that the allegations in the complaint failed to state a legal ground for annulment. The claim that the court “fraudulently rendered a decision knowing… it has no jurisdiction” was a mere conclusion of law without supporting ultimate facts. The allegation regarding the court’s disregard of Manuel Bautista’s testimony pertained to the appreciation of evidence, which is an intrinsic matter within the court’s adjudicatory function, not extrinsic fraud.
The Court explained that only extrinsic fraud is a ground for annulment of judgment. Extrinsic fraud refers to a fraudulent act committed outside the trial that prevents a party from fully and fairly presenting their case, such as keeping a party away from court or concealing the existence of a defense. Intrinsic fraud, which pertains to matters litigated and adjudicated within the trial like perjury or falsified evidence, cannot be a basis for annulment. The plaintiffs’ allegations concerning the lease contract and the court’s evaluation of witness testimony were intrinsic to the original litigation. The dismissal was proper as the complaint, on its face, failed to assert a sufficient cause of action for annulment based on extrinsic fraud or lack of jurisdiction, and the action effectively sought to relitigate issues already conclusively settled by a final judgment.
