Case Digest (G.R. No. 128686)
Facts:
- Honorato Espinosa is the petitioner against the Court of Appeals, Hon. Presiding Judge Tito G. Gustilo of the RTC of Iloilo City, and spouses Rodolfo and Violeta Alcantara as respondents.
- The case began on November 4, 1985, when the Alcantaras filed an ejectment action against Espinosa, claiming his restaurant encroached on their property, Lot 933-A-1-A, covered by Transfer Certificate of Title No. T-69242.
- Espinosa denied the allegations, asserting his restaurant was on Lot 933-A-18, which he owned.
- The MTC ruled in favor of Espinosa on February 6, 1989, dismissing the complaint and awarding him damages.
- The Alcantaras appealed to the RTC, which ordered a relocation survey to determine property boundaries.
- The survey revealed Espinosa's restaurant encroached on 89 square meters of the Alcantaras' lot and part of the city street.
- Espinosa rejected a proposed compromise settlement by Judge Gustilo.
- On May 15, 1990, the RTC reversed the MTC's decision, ordering Espinosa to vacate the property and pay damages.
- Espinosa filed a Petition for Review with the Court of Appeals, which was denied on September 6, 1993.
- After exhausting appeals, Espinosa filed a petition for annulment of judgment on December 6, 1995, citing extrinsic fraud and denial of due process.
- The Court of Appeals dismissed the petition and found Espinosa and his counsel in contempt for forum-shopping.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the RTC Decision cannot be annulled on the grounds of extrinsic fraud and denial of due process.
- The Court affirmed the findi...(Unlock)
Ratio:
- The Supreme Court stated that annulment of judgment is an equitable remedy available only in exceptional cases where no other adequate remedy exists.
- While extrinsic fraud is a valid ground for annulment, mere allegations are insufficient; the claimant must prove the fraud definitively.
- Espinosa's claim of extrinsic fraud was based on a relocation survey conducted during the appeal, which was deemed a lawful order by the RTC, agreed upon by all parties.
- The Court noted that Espinosa had multiple chances to contest the survey's findings in prior appeals, indic...continue reading
Case Digest (G.R. No. 128686)
Facts:
The case involves Honorato Espinosa as the petitioner and the Court of Appeals, Hon. Presiding Judge Tito G. Gustilo of the Regional Trial Court (RTC) of Iloilo City, and spouses Rodolfo and Violeta Alcantara as respondents. The events leading to this case began on November 4, 1985, when the Alcantaras filed an ejectment action against Espinosa, claiming that his restaurant, Tatoy's Manokan and Seafoods Restaurant, encroached upon their property, Lot 933-A-1-A, covered by Transfer Certificate of Title No. T-69242. Espinosa denied the allegations, asserting that his restaurant was situated on Lot 933-A-18, which he owned. The Municipal Trial Court in Cities (MTC) ruled in favor of Espinosa on February 6, 1989, dismissing the complaint and awarding damages to him. The Alcantaras appealed this decision to the RTC, which ordered a relocation survey to determine the exact boundaries of the properties involved. The survey revealed that Espinosa's restaurant encroached on 89 square meters of the Alcantaras' lot and a portion of the city street. Despite a proposed compromise settlement by Judge Gustilo, Espinosa rejected the offer. On May 15, 1990, the RTC reversed the MTC's decision, ordering Espinosa to vacate the property and pay damages to the Alcantaras. Espinosa subsequently filed a Petition for Review with the Court of Appeals, which was denied on September 6...