G.R. No. 102900 - Arcelona vs. Court of Appeals

Petitioners Marcelino Arcelona, Tomasa Arcelona-Chiang and Ruth Arcelona (naturalized U.S. citizens) are co-owners pro indiviso of a fishpond in Dagupan City under TCT No. 34341, together with their siblings Pacita Arcelona-Olanday, Maria Arcelona-Arellano, Natividad Arcelona-Cruz and the late Benedicto Arcelona (represented by Ruth).
The fishpond was inherited from their parents and remains undivided; ownership shares are not physically segregated.

On March 4, 1978, co-owners Olanday et al. leased the entire fishpond to Cipriano Tandoc for three years, renewed to February 2, 1984. Tandoc appointed Moises Farnacio as caretaker-tenant on the same date.
After lease expiration, Tandoc validly surrendered possession; on February 7, 1984, Farnacio filed Civil Case No. D-7240 in the R.T.C. of Dagupan City, Branch 40, seeking (a) peaceful possession and security of tenure; and (b) damages, with an interlocutory order.
On October 31, 1984, the trial court declared Farnacio tenant-caretaker of the entire fishpond; defendants were ordered to maintain his possession.
The Intermediate Appellate Court affirmed with slight modification (May 31, 1985); this Court in G.R. No. 71217 (Aug. 30, 1990) sustained the IAC decision. On remand, Farnacio was placed in possession (May 25, 1991).
Petitioners then filed in the Court of Appeals a petition to annul the final and executory judgment and questioned the implementing sheriff (CA G.R. SP No. 24846). The CA:

Petitioners elevated the CA decision to this Court by petition for review (filed May 10, 1992).

Whether final and executory judgments may be annulled on grounds other than extrinsic fraud—specifically, lack of jurisdiction over subject matter or persons of indispensable parties, and denial of due process.
Whether extraneous matters not appearing in the original case record may be used to void a final judgment.
Whether an independent action for annulment in the Court of Appeals lies, or petitioners were limited to intervening in the proceedings of the court of origin.