Case Summary (G.R. No. 37044)
Procedural history in the trial court and appellate court
The petitioners originally filed a complaint in the Regional Trial Court of Capas seeking, among other reliefs, annulment of an earlier appellate judgment that ordered turnover of ownership and possession of disputed property to Marcelo Gutierrez. The petitioners alleged that Gutierrez obtained ownership by fraud by fabricating filiation to the alleged deceased owners. The RTC dismissed the complaint for lack of jurisdiction to annul a Court of Appeals judgment. The petitioners then sought relief from the Intermediate Appellate Court by petition for certiorari, mandamus and injunction, which the IAC dismissed for lack of jurisdiction and later on the merits, reasoning that only the Supreme Court could annul a decision of the Court of Appeals and that the alleged fraud was, in any event, only intrinsic.
Supreme Court remand to the Intermediate Appellate Court
The Supreme Court intervened and remanded the action to the Intermediate Appellate Court for decision on the merits, concluding that the IAC erred in declaring that the annulment action should have been filed with the Supreme Court. The Supreme Court observed that Section 9 of B.P. No. 129 vests in the Intermediate Appellate Court exclusive jurisdiction over actions for annulment of judgments of regional trial courts and that, given the procedural posture of the case (an appellate judgment rendered on review of a trial court decision), the IAC should hear and decide the annulment action.
The Intermediate Appellate Court’s decision on remand
On remand the IAC dismissed the petition for lack of jurisdiction and for lack of merit. With respect to jurisdiction, the IAC reasoned that because the annullability of a decision proceeds in stages (Metropolitan Trial Court → Regional Trial Court → Court of Appeals), logically a final appellate judgment should be annulable only by the Supreme Court and the IAC lacked power to annul its own decision absent an express grant in B.P. No. 129. On the merits the IAC concluded that the alleged fraud was intrinsic — consisting of fabricated documents and evidence regarding filiation — and thus insufficient to support annulment of the judgment.
Supreme Court’s analysis of the IAC’s remand decision
The Supreme Court criticized the IAC for revisiting jurisdiction when the remand order required a merits determination, and emphasized the organizational role of the IAC in synthesizing facts and issues for the Court. The Court noted that once it remanded the case for decision on the merits, the IAC should have confined itself to resolving the substantive allegations of fraud rather than reasserting lack of jurisdiction. The Court reiterated the limited function of the Supreme Court to review questions of law, while recognizing instances where further fact-finding by an intermediate appellate tribunal is desirable.
Determination on the nature of the alleged fraud
The Supreme Court reviewed the allegations and the record and concluded that, even assuming the petitioners’ factual allegations were true, the fraud alleged was intrinsic in character. The Court explained the conventional distinction: extrinsic fraud prevents a party from having a trial or
...continue readingCase Syllabus (G.R. No. 37044)
Nature of the Action and Relief Sought
- Petitioners filed, on January 16, 1984, an action to annul the judgment of the Court of Appeals dated September 23, 1981, which had reversed the Regional Trial Court decision and ordered the petitioners and/or their successors-in-interest to deliver immediately the ownership and possession of the property in question to Marcelo Gutierrez.
- The complaint alleged that Marcelo Gutierrez, through fraud, made it appear that he was the son of Esteban Gutierrez and Fermina Ramos and that, as a consequence of such filiation, he was the absolute owner by succession of the disputed property.
- The relief sought was annulment of the Court of Appeals judgment that had ordered turnover of the property to Marcelo Gutierrez.
Trial Court Proceedings and Initial Dismissal
- The Regional Trial Court of Capas, Tarlac dismissed the petitioners’ complaint on February 27, 1984, on the ground that it had no jurisdiction to annul the judgment of the Court of Appeals.
- The trial court denied the petitioners’ motion for reconsideration (the denial is recorded in the appellate court narration of subsequent proceedings).
- Following denial, the petitioners filed a petition for certiorari, mandamus and a writ of injunction before the Intermediate Appellate Court challenging the dismissal.
Intermediate Appellate Court’s Initial Action and Dismissal
- The Intermediate Appellate Court dismissed the petition for certiorari, mandamus and a writ of injunction, and denied a subsequent motion for reconsideration, on the grounds that:
- A Regional Trial Court is without jurisdiction to annul the judgment of the Court of Appeals.
- Only the Supreme Court is empowered to review the judgment of the Court of Appeals.
- The appellate court’s dismissal was based on its view of the limits of jurisdiction among the courts and the appellate hierarchy.
Supreme Court Remand (Resolution of August 22, 1984; Issued August 31, 1984)
- The Supreme Court issued a resolution dated August 22, 1984 (entered August 31, 1984), remanding the case to the Intermediate Appellate Court for decision on the merits.
- The remand resolution explained:
- The Intermediate Appellate Court erred in declaring that the complaint for annulment of judgment should be filed with the Supreme Court.
- The Supreme Court stated it has no original jurisdiction to look into allegations of fraud upon which the complaint for annulment is based.
- The Court observed that although the judgment being enforced was that of the Court of Appeals, it was an appellate judgment rendered on a review of the trial court’s decision and, under Section 9 of the Judiciary Reorganization Act of 1980 (B.P. No. 129), the Intermediate Appellate Court has exclusive jurisdiction over actions for annulment of judgments of regional trial courts.
- The Supreme Court therefore resolved to remand the case to the Intermediate Appellate Court for it to hear and decide the action.
Intermediate Appellate Court Decision on Remand (January 29, 1985)
- On January 29, 1985, the Intermediate Appellate Court rendered a decision dismissing the petition for lack of jurisdiction and for lack of merit.
- On jurisdiction, the appellate court reasoned:
- If a decision of the Metropolitan Trial Court can be annulled by the Regional Trial Court, and a decision of the Regional Trial Court is annullable by the Court of Appeals, then logically the decision of the Court of Appeals should be annullable only by the Supreme Court.
- The appellate court concluded that it cannot annul its own decision unless there is an express grant under the Judiciary Reorganization Act of 1980, and finding none, it held it must dismiss the case for lack of jurisdiction.
- On the merits, the appellate court held that the fraud alleged by the petitioners was intrinsic in character and therefore insufficient to ground an action for annulment of judgment; consequently, the petition lacked merit and was dismissed.
Underlying Factual Background and Prior Proceedings (As Recited by the Appellate Court)
- An original complaint for recovery of possession of a parcel of land was filed in February 1950 before the Court of First Instance of Tarlac, amended on March 19, 1951.
- On May 20, 1976, after a full-blown trial, the Regional Trial Court, Branch 64 (formerly Court of First Instance) of Tarlac rendered a decision dismissing the complaint and ordering plaintiff Marcelo Gutierrez to pay the defendants the costs of suit. The dispositive portion read in part: “WHEREFORE, judgment is hereby rendered dismissing the complaint and ordering plaintiff Marcelo Gutierrez to pay the defendants the costs of this suit. He (sic) pronouncement as to damages for want of proof.”
- An appeal was filed with the Court of Appeals.
- On September 23, 1981, the Court of Ap