Facts:

The case involves a petition for review on certiorari filed by Cresenciano C. Bobis, Bonifacio Consulta, Gimeno Buara, Porferio Bueno, Melchor Codorniz, spouses Rolando Bola and Avelina V. Bola, and Jose Satuito (collectively referred to as petitioners) against the Court of Appeals, Hon. Geronimo R. San Jose, Jr., the Regional Trial Court of Tabaco, Albay, Branch 18, Adrian Azupardo, Deputy Sheriff, and the heirs of Julian Britanico (respondents). The case originated from a complaint filed on December 20, 1977, by Julian Britanico, the predecessor-in-interest of the private respondents, against several defendants for quieting of title concerning a parcel of land located in Barrio Bangkilingan, Tabaco, Albay. The land in question, part of Lot No. 1399, measures approximately 1,012 square meters and is bounded by various parties.

During the trial, the defendants failed to appear, and some expressed they no longer claimed any interest in the property. Consequently, the trial ...

Facts:

1. Parties Involved:

   • Petitioners: Cresenciano C. Bobis, Bonifacio Consulta, Gimeno Buara, Porferio Bueno, Melchor Codorniz, Spouses Rolando Bola and Avelina V. Bola, and Jose Satuito.
   • Respondents: Court of Appeals, Hon. Geronimo R. San Jose, Jr. (Presiding Judge, RTC of Tabaco, Albay, Branch 18), Adrian Azupardo (Deputy Sheriff), and the Heirs of Julian Britanico.

2. Subject Property:

   • A parcel of land in Barrio Bangkilingan, Tabaco, Albay, with an area of 1,012 square meters, part of Lot No. 1399.

3. Origins of the Dispute:

   • Julian Britanico (respondents' predecessor) filed a complaint for quieting of title on December 20, 1977, against Benjamin Bolivar, Juanito Bataller, Nicolas Breva, Eugenio Avila, and Eduardo Bueno (Civil Case No. T-417).
   • Julian Britanico claimed ownership of the land, having purchased it from Eusebio, Sofronia, Fortunata, and Fidela Breva in 1973.

4. Trial Court Proceedings:

   • Defendants repeatedly failed to appear in court. Benjamin Bolivar and Eugenio Avila eventually disclaimed any interest in the land.
   • The trial court allowed Julian Britanico to present evidence ex parte and ruled in his favor on October 19, 1989, declaring him the absolute owner of the property.

5. Post-Judgment Events:

   • Julian Britanico died and was substituted by his heirs (respondents).
   • A writ of execution was issued but returned unsatisfied due to eight houses constructed on the property by petitioners.
   • Respondents filed a motion for a writ of demolition, which petitioners opposed, claiming ownership of the houses and the land.

6. Petitioners' Claims:

   • Petitioners argued that they were not parties to Civil Case No. T-417 and that the decision could not bind them.
   • They alleged that the sale to Julian Britanico was dubious and that they acquired the land from Eugenia, Fidela, and Fortunata Breva between 1966 and 1981.

7. Court of Appeals Decision:

   • The Court of Appeals dismissed the petition for annulment of judgment on December 15, 1993, prompting petitioners to elevate the case to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Grounds for Annulment of Judgment:

   • A judgment may be annulled only if it is void for lack of jurisdiction or due process, or if it was obtained through extrinsic fraud.
   • Extrinsic fraud refers to acts committed outside the trial that prevent a party from fully presenting their case.

2. Extrinsic Fraud vs. Intrinsic Fraud:

   • Extrinsic fraud involves acts that prevent a party from participating in the trial (e.g., keeping a party away from court or using fraudulent means to prevent a fair hearing).
   • Intrinsic fraud, such as the use of forged documents or perjured testimony, does not justify annulment as it pertains to evidence presented during the trial.

3. Due Process:

   • Petitioners were not denied due process. They were given opportunities to oppose the writ of demolition and file motions for reconsideration.

4. Petitioners' Inaction:

   • Petitioners' failure to intervene in Civil Case No. T-417 and their delay in asserting their claims contributed to their predicament.