G.R. No. 190340 - People vs. Ramos

On November 21, 1995 and January 30, 1996, Spouses Raul and Cristina Acampado obtained loans of ₱5,000,000 and ₱2,000,000, respectively, from Metropolitan Bank and Trust Company (Metrobank).
To secure payment, the Acampados executed a Real Estate Mortgage (registered November 20, 1995) and an Amendment of Real Estate Mortgage (registered January 23, 1996) over a parcel covered by Transfer Certificate of Title (TCT) No. V-41319 in the Registry of Deeds of Valenzuela City.

On June 3, 1996, Sy Tan Se filed in RTC Valenzuela, Branch 172, Civil Case No. 4930-V-96 for declaration of nullity of TCT No. V-41319. Metrobank, as registered mortgagee, was neither impleaded nor notified.
After the Acampados defaulted, Metrobank initiated extrajudicial foreclosure on April 19, 1997. On June 17, 1997 a sheriff’s auction was held; Metrobank submitted the highest bid and on July 15, 1997 received a Certificate of Sale, registered July 28, 1997. Upon lapse of the one-year redemption period, Metrobank executed an Affidavit of Consolidation of Ownership seeking issuance of a new TCT.
On July 28, 1998 Metrobank learned of the August 12, 1998 RTC Decision in Civil Case No. 4930-V-96, which declared TCT No. V-41319 null and void. On January 27, 1999 Metrobank petitioned the Court of Appeals (CA) for annulment of judgment; the CA dismissed the petition for insufficiency (March 25, 1999) and denied reconsideration (January 27, 2000). Metrobank then filed a petition for review on certiorari under Rule 45 in the Supreme Court.

Whether a petition for annulment of judgment under Rule 47 is the proper remedy available to Metrobank in the circumstances.
Whether the RTC Decision in Civil Case No. 4930-V-96 should be annulled for lack of jurisdiction.