Case Summary (G.R. No. 249815)
RTC Grant of Petition and Issuance of Title
In its December 10, 2012 Decision (amended June 27, 2013), RTC Branch 83 declared a general default, canceled TCT No. 57394 (PR-11986), and ordered the Register of Deeds to issue a new title to Chico. A writ of possession was also directed. Finality of the amended decision was attained on April 7, 2015, and TCT No. 004-2016005243 was issued in Chico’s favor.
Petition for Annulment by Ciudadano
In January 2017, Ciudadano filed a petition for annulment of judgment with the CA, alleging extrinsic fraud and lack of jurisdiction. She asserted that she and her husband had acquired the property via a notarized June 23, 1989 Deed of Absolute Sale duly annotated on TCT No. 57394, and had occupied the land as their family home since 1992. She was never notified of Chico’s petition for new title and discovered the proceedings only upon receiving a writ of possession notice in November 2016.
CA Decision Annuling RTC Judgments
The CA granted Ciudadano’s petition on April 5, 2019, finding that:
- Ciudadano was an indispensable and real party in interest by virtue of her registered and annotated 1989 sale and long possession.
- Chico deliberately failed to implead or notify Ciudadano, constituting extrinsic fraud.
- The RTC thus lacked jurisdiction over Ciudadano, violating her due process rights.
The CA set aside both the original and amended RTC decisions, voided Chico’s TCT No. 004-2016005243, and reinstated TCT No. 57394 in Bengzon’s name. A motion for reconsideration was denied on October 8, 2019.
Supreme Court’s Grounds on Annulment of Judgment
The Supreme Court affirmed the CA, emphasizing that under Rule 47 only extrinsic fraud and lack of jurisdiction justify annulment of judgment. It reiterated that the remedy is extraordinary and not a substitute for ordinary remedies. Extrinsic fraud must be committed by the prevailing party outside of trial and must have prevented the aggrieved party from fully presenting the case. Lack of jurisdiction may arise from failure to serve a real party in interest, depriving the court of authority over that person.
Real Party in Interest and Extrinsic Fraud
– Rule 3, Section 2, requires actions to be brought by real parties in interest, defined by material interest in the subject matter.
– Ciudadano’s notarized 1989 Deed, registered on the title, conferred presumption of validity and constructive notice to all.
– Despite actual and constructive knowledge of Ciudadano’s sale and occupation (including observable improvements), Chico omitted her from the petition.
– Such deliberate exclusion constituted extrinsic fraud, justifying annulment since the fraudulent scheme prevented Ciudadano from having her day in court.
Lack of Jurisdiction and Due Process Violations
– Chico’s petition did not provide the address of the occupied premises, preventing service of notices on Ciudadano.
– Absence of service deprived the RTC of jurisdiction over her person, violating
Case Syllabus (G.R. No. 249815)
Antecedents
- On April 10, 2012, petitioner Gloria A. Chico filed before the RTC of Quezon City (Branch 83, LRC Case No. Q-33350(12)) a Petition for Issuance of a New Title under Sections 75 and 107 of PD No. 1529.
- She alleged she was the highest bidder in the July 8, 2010 Tax Delinquency Sale of a parcel covered by TCT No. 57394 (PR-11986), originally registered in the name of Rosalita G. Bengzon.
- After the lapse of the one-year redemption period, the Quezon City Treasurer executed a Final Bill of Sale conveying the property to Chico.
- Chico prayed for cancellation of the existing TCT and issuance of a new one in her name, appending copies of:
• TCT No. 57394 (PR-11986)
• Correlative tax declaration
• Warrant and notice of levy
• July 30, 2010 Certificate of Sale
• January 12, 2012 Final Bill of Sale
• Property identification map - Notices of hearing were served on Chico, her counsel, the Office of the Solicitor General, LRA Administrator, Register of Deeds of Quezon City, City Prosecutor, City Attorney and were posted in public places.
Regional Trial Court Proceedings
- RTC issued on May 24, 2012 an Order declaring general default for lack of opposition.
- In its December 10, 2012 Decision, RTC:
• Granted the petition dated August 4, 2012
• Ordered cancellation of TCT No. 57394 (PR-11986)
• Directed issuance of a new TCT in Chico’s name
• Issued a Writ of Possession directing the deputy sheriff to place Chico in actual possession and eject all occupants - RD-QC cancelled the old TCT and issued TCT No. 004-2016005243 in Chico’s name.
- Chico moved to amend the December 10, 2012 Decision to correct the title number; on June 27, 2013, RTC issued an Amended Decision deleting the “RT” prefix.
- Certificates of Finality issued: February 22, 2013 (original) and April 7, 2015 (amended).
- Chico filed a separate Petition for Writ of Possession (LRC Case No. R-QZN-16-08936-LR), leading to a Branch 96 order for initial presentation of evidence on December 9, 2016.