G.R. No. 140984 - Joven vs. Calilung

G.R. No. 140984 – filed by Emiliano D. Joven seeking to annul the RTC Branch 60 decision dismissing his complaint for annulment of judgment and denying his motion for reconsideration.
G.R. No. 148970 – filed by Federico S. Calilung questioning the Court of Appeals’ decision which reversed the RTC decision that disqualified Joven’s counsel and expunged his pleadings, as well as denying his motion to suspend further proceedings.

Both petitions originated from an action for unlawful detainer initiated by Calilung against Joven before the Municipal Trial Court in Cities (MTCC), Branch II, Angeles City.
The underlying ejectment action involved allegations that Joven and persons claiming under him should vacate a leased premises, with Joven being ordered to pay monthly rental, attorney’s fees, and other costs.

On December 4, 1998, Judge Wilfred S. Suriaga of MTCC rendered a decision in favor of Calilung, ordering Joven to vacate the premises and pay monthly rent and attorney's fees.
Joven appealed the decision on December 23, 1998, filing his case before RTC Branch 58, where Judge Philbert Iturralde presided. Despite this, Calilung pursued a separate motion for execution in MTCC, which was denied.
Later, Calilung filed a motion to dismiss the appeal, and it was denied.
On April 16, 1999, Calilung submitted a sworn statement to the National Bureau of Investigation (NBI) alleging that Judge Suriaga demanded and received bribes (P300,000.00 and P250,000.00) in exchange for a favorable decision in the ejectment case.
Based on Calilung’s statement, the NBI conducted an entrapment operation on April 19, 1999 that led to the arrest of Judge Suriaga; subsequently, both Judge Suriaga and Judge Iturralde were placed under preventive suspension by a court resolution on May 4, 1999.

On May 10, 1999, Joven filed a complaint for annulment of judgment before RTC Branch 60 alleging extrinsic fraud due to the bribery of Judge Suriaga, seeking a new trial. This case was docketed as Civil Case No. 9399.
Simultaneously, in Civil Case No. 9314 before RTC Branch 58, Joven filed a motion to suspend further proceedings on the ground that the judgment had been procured by corruption and that a pending annulment complaint existed.
Calilung countered in Civil Case No. 9314 by filing motions to withdraw monthly rental deposits and to disqualify Joven’s counsel (Atty. Carmelino Roque), including a motion to expunge all pleadings filed by said counsel.
On May 24, 1999, Judge Ofelia Tuazon-Pinto of RTC Branch 60 issued an order granting:

The motion to withdraw monthly rental deposits (including the release of March 1999 rental and the supersedeas bond).
The motion to disqualify Joven’s counsel by expunging the pleadings filed by Atty. Roque.
The motion to suspend the appeal proceedings was denied.

On May 26, 1999, Judge Pinto promulgated a decision affirming in toto the ejectment judgment rendered by Judge Suriaga on December 4, 1998.
On June 3, 1999, the Court of Appeals instructed Judge Pinto to maintain the status quo, enjoining further proceedings in Civil Case No. 9314.
On August 16, 1999, RTC Branch 60 dismissed Joven’s petition for annulment of judgment on the ground that the case was moot since the ejectment decision had been superseded by ongoing appellate proceedings.
Joven sought a reconsideration of the dismissal on grounds including:

The RTC decision of May 26, 1999 was not fully effective because it was enjoined by the Court of Appeals and thus was under judicial review.
The extrinsic fraud claim regarding the timing of the discovery and subsequent actions.
The issue of judicial inhibition regarding Judge Pinto’s decision.

On November 29, 1999, Joven’s motion for reconsideration was denied.
Joven, unsatisfied with the various rulings, filed a Petition for Review on Certiorari directly with the Supreme Court on January 20, 2000.
In a related administrative case decided on August 31, 2000, the Court found Judge Suriaga guilty of bribery and serious misconduct, dismissing him from service with consequent penalties.
On March 19, 2001, the Court of Appeals rendered its decision (in G.R. No. 148970) ordering the suspension of the judgment’s effect and reassigning Civil Case No. 9399, among other reliefs.
Finally, the petitions were consolidated before the Supreme Court, focusing on the central issue of whether the ejectment judgment dated December 4, 1998, should be annulled on the ground of extrinsic fraud due to bribery.

Whether the ejectment judgment rendered on December 4, 1998, which was procured by bribery, constituted a judgment tainted by extrinsic fraud.

Did the bribery of Judge Suriaga by Calilung, resulting in a predetermined outcome, deprive Joven of his right to a fair trial?
Is the conduct of demanding and receiving money from a party in a case, as alleged, sufficient to establish extrinsic fraud that vitiates the judicial decision?

Whether it is proper to annul the ejectment judgment on the basis that the decision was obtained through extrinsic fraud, and whether a new trial should be ordered.

Can the subsequent administrative conviction and dismissal of Judge Suriaga for bribery be used as a basis to invalidate the lower court decision?
Is the extrinsic fraud doctrine applicable when the fraudulent act occurred outside the trial and prevented full presentation of the case?

The effect of the Court of Appeals’ orders to suspend the judgment’s enforcement pending a final resolution of the annulment proceedings.
Whether the actions taken by the RTC and CA regarding motions and disqualifications are moot in view of the nullification of the judgment due to extrinsic fraud.