G.R. No. L-24080 - Cordovis vs. De Obias

The original dispute arose over two parcels of land in Garchitorena, Camarines Sur.
The plaintiffs—Hermogenes P. Obias (deceased and substituted by his children) and Basilisa A. de Obias—filed an action to quiet title against several defendants (Juan, Catalina, Patricia, Simeon and Nemesia Cordovis, Marciano Rodavia, Teodora Beronio, Tomas Areega, Alejandro Frias, Troadio Mijares, Sixto Lopez, and Agustin Belmonte) in Civil Case No. 3660 of the Court of First Instance of Camarines Sur.
Both plaintiffs and defendants claimed ownership and possession of the lands.

During the trial, the plaintiffs presented evidence supporting their right to the land, after which they rested their case.
The defendants moved for dismissal, arguing that there was no believable proof showing that they had violated the plaintiffs’ legal rights.
The trial court granted the motion to dismiss on the basis that the evidence presented by the plaintiffs did not warrant interfering with the defendants’ possession and title.

The plaintiffs appealed the trial court’s dismissal to the Court of Appeals.
In case CA-G.R. No. 25280-R, the appellate court found the plaintiffs’ evidence sufficient to support the quiet title action.
The Court of Appeals invoked the principle that the defendants were barred from presenting their evidence due to the demurrer to the plaintiffs’ evidence.
The appellate court reversed the trial court’s dismissal, declared the plaintiffs as the rightful owners and possessors, and issued an injunction restraining the defendants from disturbing the plaintiffs’ title and possession.
The decision of the Court of Appeals became final and executory.

All losing defendants in Civil Case No. 3660 (except Sixto Lopez) subsequently filed a complaint with the Court of First Instance (Civil Case No. T-115) to annul the CA judgment.
The grounds alleged in the complaint were that the plaintiffs had falsely stated in the prior proceedings that they were in possession of the lands, thereby misleading both the Court of First Instance and the Court of Appeals.
Additional allegations included claims that the plaintiffs had solicited aid from the Philippine Constabulary to enter the lands and that a previous forcible entry complaint by the Obias spouses was dismissed.

The plaintiffs-appellants in the annulment complaint were represented by Atty. Ezekiel S. Grageda, while on appeal Atty. Vicente L. Arcega entered his appearance for Tomas Arcega.
A discrepancy arose when Atty. Arcega’s brief included the name Vicente Mapada, who was not a party to the case; the court warned against such misrepresentations.
The legal arguments also touched on prior decisions, including reference to Anuran vs. Aquino, regarding the nature and impact of fraud in procured judgments.

Whether the alleged fraud or perjury committed by the plaintiffs in the quiet title action (Civil Case No. 3660) constitutes extrinsic fraud sufficient to set aside the final and executory judgment of the Court of Appeals.

Does the allegation that the plaintiffs falsely stated their possession of the lands provide a ground to annull a final judgment?
Can intrinsic fraud—fraud that was part of the issues presented and considered by the courts—serve as a basis for annulling the judgment?

Whether the doctrine of res judicata applies in this case despite the plaintiffs’ attempt to challenge the final judgment on the ground of alleged fraud.

Is the judgment in Civil Case No. 3660 protected by res judicata even if fraud is alleged in its procurement?
How does the application of res judicata interact with the claim of misrepresentation and perjury in the proceedings?

Whether the reference to a prior forcible entry case, as argued by Atty. Arcega, affects or undermines the finality of the quiet title judgment.

Can a decision in a forcible entry case have an effect on the quiet title action’s outcome regarding ownership?