Title
Avedana vs. Bautista
Case
G.R. No. L-52092
Decision Date
Apr 8, 1986
Plaintiffs sought to annul a prior land possession judgment, alleging fraud and bad faith. The Supreme Court dismissed the case, citing res judicata and insufficient evidence of extrinsic fraud.
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Case Digest (G.R. No. L-52092)

Facts:

Background of the Case:

  • Plaintiffs-appellants Leonardo Avedana and Purificacion Timbang filed a complaint to annul the judgment rendered by the Court of First Instance of Rizal in Civil Case No. 3782-P.
  • The original case (Civil Case No. 3782-P) was filed by defendant-appellee Manolito Bautista for the recovery of possession of a parcel of land. Plaintiffs-appellants claimed to be lessees of the land under a lease contract allegedly executed between Manuel Bautista (father of Manolito Bautista) and Fausta Timbang (mother of the plaintiffs-appellants).

Decision in Civil Case No. 3782-P:

  • The Court of First Instance of Rizal ruled in favor of Manolito Bautista on May 26, 1973.
  • Plaintiffs-appellants appealed to the Court of Appeals, which affirmed the decision with modifications on February 11, 1977.

Allegations in the Annulment Case:

  • Plaintiffs-appellants alleged that the Court of First Instance acted in "evident bad faith" and rendered a fraudulent decision, knowing it lacked jurisdiction over the case.
  • They claimed that the court disregarded the testimony of Manuel Bautista, a hostile witness, to their detriment.
  • Plaintiffs-appellants argued that Manolito Bautista, as the heir of Manuel Bautista, was bound by the lease agreement executed between Manuel Bautista and Fausta Timbang.

Motion to Dismiss:

  • Defendant Manolito Bautista filed a motion to dismiss, arguing that the plaintiffs' cause of action was barred by prior judgment and that the complaint was a tactic to delay the execution of the final decision in Civil Case No. 3782-P.
  • The Court of First Instance granted the motion to dismiss on March 29, 1978, and denied plaintiffs' motion for reconsideration.

Appeal to the Supreme Court:

  • Plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court as involving purely questions of law.

Issue:

  1. Whether the complaint for annulment of judgment filed by plaintiffs-appellants is barred by prior judgment.
  2. Whether the allegations of fraud in the complaint constitute sufficient grounds for annulment of the judgment in Civil Case No. 3782-P.
  3. Whether the trial court properly dismissed the complaint for lack of cause of action.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court dismissed the appeal, affirming the lower court's order dismissing the complaint. The Court emphasized that litigations must come to an end, and parties cannot use allegations of intrinsic fraud to relitigate issues already decided by a final judgment.


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