Title
Bobis vs. Court of Appeals
Case
G.R. No. 113796
Decision Date
Dec 14, 2000
A group of petitioners fails to prove extrinsic fraud in their attempt to annul a decision in a quieting of title case, resulting in the Court of Appeals dismissing their petition and affirming the decision of the trial court.
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Case Digest (G.R. No. 113796)

Facts:

  • The case Cresenciano C. Bobis et al. v. Court of Appeals (G.R. No. 113796) was decided by the Supreme Court on December 14, 2000.
  • Petitioners included Cresenciano C. Bobis, Bonifacio Consulta, Gimeno Buara, Porferio Bueno, Melchor Codorniz, and spouses Rolando and Avelina Bola, along with Jose Satuito.
  • They sought to annul a decision from the Regional Trial Court of Tabaco, Albay, Branch 18, in Civil Case No. T-417.
  • The case began on December 20, 1977, when Julian Britanico filed a complaint for quieting of title against several defendants, including Benjamin Bolivar, concerning a 1,012 square meter parcel of land in Barrio Bangkilingan, Tabaco, Albay.
  • Britanico acquired the land through a deed of sale dated November 13, 1973.
  • The defendants, including the petitioners, failed to appear in court, resulting in an ex-parte presentation of evidence by Britanico.
  • On October 19, 1989, the trial court ruled in favor of Britanico, declaring him the absolute owner and awarding damages against the absent defendants.
  • After Britanico's death, his heirs pursued the case and sought a writ of demolition against the petitioners, who had constructed eight houses on the disputed land.
  • The trial court initially denied the demolition motion but later granted it upon reconsideration.
  • The petitioners filed a petition for annulment, alleging that extrinsic fraud impeded their case presentation.
  • The Court of Appeals dismissed their petition on December 15, 1993, prompting the petitioners to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Court of Appeals' decision, dismissing the petition for review on certiorari.
  • The Court determined that the petitioners failed to demonstrate the existence of extrinsic fraud necessary for annulling the trial court's decis...(Unlock)

Ratio:

  • The Supreme Court clarified that for a judgment to be annulled due to fraud, it must be extrinsic or collateral, preventing a party from having a fair trial.
  • The Court found no evidence of extrinsic fraud; the petitioners were aware of the litigation since 1981 but opt...continue reading

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