G.R. No. 164482 - Estrellado vs. Presiding Judge of the Municipal Trial Court in Cities, 11th Judicial Region, Branch 3, Davao City

The properties in issue consist of three adjacent parcels of land located in Barangay Matina-Aplaya, Davao City, originally owned by the Estrellado and Barredo families.
Each parcel was subdivided into two portions: a smaller lot of 5,000 square meters and a larger lot of approximately 10,465 square meters.
The former owners were related by consanguinity or affinity, and their respective successors-in-interest and heirs became the petitioners and respondents in the consolidated appeals.

In September 1967, the Spouses Eugene and Lourdes Estrellado sold their 5,000-square meter lot to Dr. Jovito S. Francisco for P10,000.00, as evidenced by a deed of absolute sale dated September 25, 1967.
Similarly, the Spouses Nicolas and Narcisa Estrellado, as well as the late Spouses Alipio and Vivina Barredo, sold their 5,000-square meter lots to Dr. Francisco on the same date and for the same price.
Subsequent sales of the larger portions of the lots were made on different dates: August 2, 1969 (by the Estrellados), October 29, 1969 (by the Estrellados), and June 10, 1970 (by the Barredos).
Although Dr. Francisco and his successors-in-interest began possession of the entire landholdings in 1967, they could not produce the formal deeds of sale regarding the larger lots, relying instead on a book of accounts evidencing installment payments.

In October 1998, J.S. Francisco & Sons, Inc. filed three forcible entry cases in the Municipal Trial Court in Cities (MTCC) in Davao City against the Estrellados.
On April 26, 1999, the MTCC rendered judgments in favor of the Franciscos, ordering the Estrellados and their successors to vacate the properties and pay various amounts including fruits of the properties, rent, attorney’s fees, litigation expenses, and costs.
The Regional Trial Court (RTC) in Davao City affirmed the MTCC’s decision on appeal on August 27, 1999, and the Court of Appeals (CA) later dismissed further appeals by the Estrellados on decisions issued on June 28, 2000, and January 24, 2003—rendering these decisions final and executory.

Petitioners, who were defendants and successors-in-interest in the forcible entry cases, filed a petition for annulment of the MTCC’s judgments on December 15, 2003.
Their grounds included allegations of extrinsic fraud—claiming that their counsel failed to present key documents—and questioning the jurisdiction of the MTCC over the cases, as well as asserting that they held valid possessory rights over the disputed lots.
Respondents moved to dismiss the petition, arguing that the judgments had already been affirmed by the RTC and CA, and that the petition was barred by res judicata, litis pendentia, forum shopping, and non-compliance with the Rules of Court regarding the certificate of non-forum shopping.
On June 11, 2004, the RTC rendered judgment dismissing the petition for annulment of judgment, also finding the petitioners’ counsel guilty of direct contempt and fining them P500.00.

The respondents, who are the heirs of the late Spouses Alipio and Vivina Barredo, initiated an action asserting their ownership over the property covered by Transfer Certificate of Title (TCT) No. T-19930.
They alleged that the execution of the forcible entry judgment would violate their rights as owners and brought actions for quieting of title and accion reinvindicatoria before the RTC (Branch 16) in Davao City.
On October 20, 2008, the RTC (Branch 16) ruled against the respondents, ordering the reinstatement of TCT No. T-19930 and imposing damages and attorney’s fees on the plaintiffs.
The respondents appealed to the CA, which on March 14, 2013, reversed the RTC’s decision and declared them the lawful and rightful owners and possessors of the property.

The Supreme Court consolidated the appeals from the petition for annulment of judgment (G.R. No. 164482) and the appeal on the property ownership case (G.R. No. 211320).
The main issues involved the availability of the remedy of annulment and the enforceability of judgments against parties not expressly impleaded, as well as the substantive question of ownership over the disputed property.

Whether the petition for annulment of judgment filed in G.R. No. 164482 is an available remedy when the judgment in the forcible entry cases has attained finality through prior appeals.

Does the extraordinary remedy for annulment extend to judgments that have already been affirmed by both the RTC and the CA?
Can extrinsic fraud allegations justify annulment even when the proper appeal remedies were previously exhausted?

Whether non-parties to the original forcible entry cases, or those bound by privity with the original parties, may validly challenge the judgment through a petition for annulment.

In the context of G.R. No. 211320, whether the CA correctly evaluated the evidence concerning the sale of the land and the possession of the owner’s duplicate copy of the TCT as proof of ownership.

Is the lack of a formal deed of sale fatal to the claim of a perfected contract of sale under Article 1475 of the Civil Code?
To what extent does the registration of a title under the Torrens system serve as conclusive evidence of ownership?

Whether the provisional adjudication in ejectment cases precludes the initiation of a later action to determine title when ownership is disputed between parties.