Case Summary (G.R. No. 113796)

Background of the Case

• The case involves a Petition for Review on Certiorari filed by petitioners against the Court of Appeals and other respondents.
• The core issue is whether extrinsic fraud vitiated the decision of the Regional Trial Court in Civil Case No. T-417, warranting its annulment.
• The original complaint was filed by Julian Britanico in 1977 for quieting of title against several defendants concerning a parcel of land in Tabaco, Albay.

Proceedings in the Trial Court

• The defendants in the original case failed to appear at hearings, leading to an ex-parte presentation of evidence by Julian Britanico.
• Britanico claimed ownership of the land based on a deed of sale from the Breva family and had paid taxes on the property.
• On October 19, 1989, the trial court ruled in favor of Britanico, declaring him the absolute owner of the property and awarding damages.

Subsequent Developments

• After Britanico's death, his heirs (the private respondents) sought to execute the judgment, but the writ of execution was returned unsatisfied due to the presence of houses on the property.
• Petitioners claimed ownership of the houses and the land, asserting that they acquired it from the Breva family.
• The trial court initially denied a motion for demolition filed by the private respondents but later granted it after reconsideration.

Petitioners' Claims

• Petitioners filed a petition to annul the trial court's decision, alleging that extrinsic fraud prevented them from presenting their case.
• They contended that they were not parties to the original case and thus the decision should not bind them.

Court of Appeals Decision

• The Court of Appeals dismissed the petition for annulment, leading petitioners to seek further review.
• The petitioners raised three main arguments regarding errors made by the Court of Appeals in upholding the trial court's decision and the writ of demolition.

Legal Standards for Annulment of Judgment

• A judgment can be annulled on two grounds: lack of jurisdiction or due process, or fraud.
• Extrinsic fraud is defined as acts that prevent a party from having a fair trial or presenting their case, as opposed to intrinsic fraud, which relates to the evidence presented during the trial.

Analysis of Extrinsic Fraud Claims

• The Court found that petitioners failed to demonstrate that extrinsic fraud occurred in the original proceedings.
• Petitioners were aware of the litigation as early as 1981 but chose not to intervene, which undermined their clai...continue reading