Case Summary (G.R. No. 102900)
Annulment on Grounds Beyond Extrinsic Fraud
The Court rejected the CA’s view that extrinsic fraud is the sole ground for annulment. It reaffirmed that a final and executory judgment may also be attacked (directly or collaterally) when jurisdiction over subject matter or personal jurisdiction is absent, or when due process is denied. Extrinsic fraud is required only when the challenged judgment is regular on its face but was procured by deception.
Jurisdiction Over Person and Due Process Violations
Due process demands valid service of summons and joinder of indispensable parties. A court acquires jurisdiction over defendants only by lawful service or voluntary appearance. A judgment against a person never served or impleaded is void and may be attacked at any time.
Exclusion of Extraneous Evidence
In collateral or direct actions to declare a judgment void for lack of jurisdiction or due process, proof must rest on the record itself—not on proof dehors the record. Extraneous matters may be introduced only in actions based on extrinsic fraud, where showing that a party was prevented by deception from a fair trial is essential.
Indispensable Parties in Co-ownership Cases
Under Rule 3, Section 7, co-owners pro indiviso whose interests are inextricably intertwined are indispensable parties. In tenancy actions affecting an undivided estate, all co-owners must be joined for a final and effective adjudication. Farnacio’s failure to implead the petitioners deprived the trial court of personal jurisdiction over them and rendered its decision void.
Independent Action Versus Intervention
Intervention during execution is not the exclusive remedy against a void judgment. Where a judgment is void for lack of jurisdiction or due process, an independent action (certiorari or direct annulment proceeding) is available. Petitioners’ absence from the country and lack of notice precluded any timely intervention; their proper remedy was a direct attack on the void judgment.
Supreme Court Conclusion
The petition succeeds. The Supreme Court held that:
• A final judgment may be annulled on grounds of lack
Case Syllabus (G.R. No. 102900)
Questions Presented
- What remedies and grounds exist to invalidate a final and executory judgment?
- May extraneous matters, not appearing in the records of the original case, be used to void such a judgment?
- Can an independent action for annulment before the Court of Appeals succeed when intervention in the trial court was available?
- Are all co-owners pro indiviso of real property indispensable parties, and does non-joinder of some invalidate the final decision?
Background Facts
- Petitioners Marcelino, Tomasa and Ruth Arcelona (naturalized U.S. citizens residing in California) and three sisters (Olanday et al.) inherited pro indiviso ownership of a fishpond (TCT No. 34341).
- On March 4, 1978, Olanday et al. leased the fishpond to Cipriano Tandoc for three years, renewed to February 2, 1984.
- Tandoc appointed Moises Farnacio as caretaker-tenant from the contract date.
- Upon lease termination, Tandoc surrendered possession; on February 7, 1984, Farnacio filed Civil Case No. D-7240 for peaceful possession, security of tenure and damages against Olanday et al.
Trial Court Proceedings
- October 31, 1984: RTC Branch 40 rendered judgment:
• Recognized Farnacio as tenant-caretaker over the entire fishpond.
• Ordered Olanday et al. to maintain Farnacio in peaceful possession and cultivation.
• Denied all other claims for lack of merit. - Olanday et al. appealed to the IAC, which affirmed with slight modification on May 31, 1985.
- Supreme Court in G.R. No. 71217 affirmed the IAC decision; after remand, Farnacio was placed in possession of the entire property on May 25, 1991.
Petition for Annulment in the Court of Appeals
- May 1991: Petitioners filed a petition in CA G.R. SP No. 24846 to annul the RTC decision as to them, alleging lack of jurisdiction, want of due process and non-impleader of indispensable parties.
- November 21, 1991: CA denied petition and reconsideration, holding that extrinsic fraud is the sole ground for annulling a final judgment and that petitioners were estopped and guilty of laches for failing to intervene earlier.
Issues on Review Before the Supreme Court
- Whether a final judgment may be annulled for lack of jurisdiction and denial of due process, aside from extri ...continue reading