Case Summary (G.R. No. 133575)
Relevant Proceedings
Lazaro obtained a loan from RFBI and subsequently failed to make payments by March 12, 1984. The bank filed a civil suit against him, which was docketed as Civil Case No. 7355-M in the RTC of Malolos, Bulacan. Lazaro was summoned at an address that was not his actual residence, leading to his default in the proceedings. Consequently, the RTC ruled in favor of RFBI on May 5, 1985, awarding the bank monetary judgment and attorney’s fees.
Further Legal Actions
In 1988, RFBI instituted another suit against Lazaro, registered as Civil Case No. 2856-V-88 in the RTC of Valenzuela City, once again using an incorrect address for service of summons. Lazaro again failed to file a responsive pleading and was declared in default. The RTC ruled in favor of the bank on August 19, 1988, instructing Lazaro to surrender property documents to RFBI, leading to further enforcement actions.
Annulment Petition
On April 29, 1999, Lazaro filed a petition for annulment of the judgments from the prior cases, alleging fraud and misrepresentation due to the incorrect address listed in RFBI's complaints. He claimed that this misrepresentation denied him due process, rendering the judgments void ab initio.
Court of Appeals' Decision
The Court of Appeals denied Lazaro's petition on June 15, 1999, noting his failure to justify why he did not pursue available remedies such as a new trial or appeal. The appellate court found no evidence of fraud related to the misstatement of his address, citing that he owned the property at the given address and would have likely received correspondence there.
Prescription of Action
Additionally, the Court pointed out that Lazaro's annulment action was time-barred, as he failed to file within four years of discovering the alleged fraud, which he claimed began in 1985 but only petitioned for annulment in 1999.
Issues Raised
The key issues in this case include whether Lazaro adequately alleged that the necessary ordinary remedies were unavailable and whether there were valid grounds for annulment due to lack of jurisdiction through improper service of summons.
Analysis of Jurisdiction
Lazaro contended that service of summons was invalid since it was not delivered to his actual residence. The court addressed the validity of the summons, stating that person
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Case Background
- The case involves petitioner Cipriano M. Lazaro and respondents Rural Bank of Francisco Balagtas (Bulacan), Inc. and the Register of Deeds of Valenzuela City.
- The petition seeks the annulment of judgments issued by the Regional Trial Courts (RTC) in two civil cases involving Lazaro and the bank.
- The Court of Appeals denied the petition for nullity on June 15, 1999, prompting Lazaro's subsequent appeal.
Facts of the Case
- Cipriano M. Lazaro borrowed money from the Rural Bank of Francisco Balagtas (RFBI) and failed to repay the loan by March 12, 1984.
- RFBI filed a complaint for collection of deficiency against Lazaro in RTC of Malolos, Bulacan, leading to Civil Case No. 7355-M.
- The complaint indicated Lazaro's address as No. 856 Esteban Street, Dalandanan, Valenzuela, Metro Manila, where summons was served.
- Lazaro did not respond, resulting in a default judgment on May 5, 1985, ordering him to pay the loan's deficiency, attorney's fees, and costs.
- RFBI later filed a second suit in RTC of Valenzuela City, Civil Case No. 2856-V-88, in which a similar default judgment was rendered on August 19, 1988, involving the surrender of the property.
Procedural History
- After RFBI executed the judgmen