Case Summary (G.R. No. L-24080)
Procedural Background
The dispute began when the plaintiffs filed an action in the Court of First Instance of Camarines Sur. Following the presentation of evidence by the plaintiffs, the defendants moved for dismissal based on a lack of credible evidence supporting the plaintiffs' claims. The trial court granted the defendants' motion, resulting in a dismissal of the case. This decision was subsequently appealed to the Court of Appeals, which reversed the trial court’s ruling, determining that the plaintiffs had sufficient evidence to support their claim. The Court of Appeals declared the plaintiffs as the rightful owners and ordered the defendants to refrain from interfering with the plaintiffs' possession.
Attempt to Annul Judgment
On April 28, 1964, several of the losing defendants from Civil Case No. 3660, excluding Sixto Lopez, initiated a separate case (Civil Case No. T-115) to annul the appellate court's judgment. They claimed that the plaintiffs had committed fraud by falsely asserting possession of the lands in prior proceedings, which allegedly misled both the trial court and the appellate court.
Grounds for Dismissal
Upon being summoned, the defendants-appellees moved to dismiss this annulment complaint. The trial court granted the motion, reasoning that the fraud alleged by the plaintiffs-appellants was not extrinsic and that the contested judgment was res judicata. This led to the conclusion that allegations could not serve as a basis for invalidating the prior judgment.
Appeal of Dismissal
Unsatisfied, the plaintiffs-appellants appealed the dismissal to a higher court. They argued that the case of Anuran v. Aquino supported their position, asserting that the circumstances constituted a form of fraud akin to that in their cited case. However, the court clarified that not all fraud constitutes grounds for annulment of a judgment; particularly, intrinsic fraud pertains to matters presented for adjudication and is not grounds for annulment.
Distinction Between Intrinsic and Extrinsic Fraud
The court drew a clear distinction between intrinsic and extrinsic fraud. The allegations made by the plaintiffs-appellants concerning false claims of ownership and possession were deemed to be intrinsic, as they involved issues that were already part of the previous case. Consequently, even if the claims of perjury were assumed to be true, they did not undermine the validity of the earlier judgment.
Res Judicata and Final Judgment
While the court acknowledged that the doctrine of res judicata could theoretically be inapplicable due to
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Background of the Case
- The case originated from a complaint to annul a judgment, filed by the plaintiffs-appellants against the defendants-appellees.
- The initial action was brought forth by the spouses Hermogenes P. Obias (deceased, with his children substituted) and Basilisa A. de Obias, seeking to quiet title over two parcels of land located in Garchitorena, Camarines Sur.
- The defendants in this action included several individuals, all surnamed Cordovis, as well as other parties such as Marciano Rodavia, Teodora Beronio, Tomas Areega, Alejandro Frias, Troadio Mijares, Sixto Lopez, and Agustin Belmonte.
- The case was docketed as Civil Case No. 3660 in the Court of First Instance of Camarines Sur.
Proceedings in the Trial Court
- Both the plaintiffs and defendants claimed ownership and possession of the disputed lands.
- Following hearings, the plaintiffs presented their evidence and rested their case.
- The defendants subsequently filed a motion for dismissal, which the trial court granted, stating there was insufficient proof that the defendants had violated any legal rights of the plaintiffs.
- The trial court's decision led to an appeal by the plaintiffs to the Court of Appeals.
Court of Appeals Ruling
- The appellate court, under case No. CA-G.R. No. 25280-R, found the evidence presented by the plaintiffs sufficient to support their claim to quiet title.
- It invoked the principle that the defendants were barred from presenting their evidence due to the demurrer filed against the plaintiffs' evidence.
- The Court of Appeals reversed the trial court's decision, recognizing