Cordovis v. Obias
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns ownership and possession of two parcels of land in Garchitorena, Camarines Sur. Spouses Hermogenes P. Obias and Basilisa A. de Obias filed an action to quiet title against several defendants, including Simeon Cordovis et al. Both parties claimed ownership and possession of the disputed properties. 2. Procedural History: The initial action, Civil Case No. 3660, was filed by the Obias spouses. After the plaintiffs presented their evidence, the defendants moved for dismissal, which the trial court granted, finding no proof of violated rights. The plaintiffs appealed to the Court of Appeals (CA-G.R. No. 25280-R). The appellate court reversed the trial court's decision, declaring the plaintiffs as rightful owners and possessors, and ordered the defendants to cease disturbing their title and possession. This decision became final and executory. Subsequently, the losing defendants (except Sixto Lopez) filed a new complaint, Civil Case No. T-115, seeking to annul the Court of Appeals' judgment. 3. The Petition: The plaintiffs in Civil Case No. T-115 appealed to the Supreme Court after their complaint to annul the judgment was dismissed by the Court of First Instance. They argued that the judgment in Civil Case No. 3660 was obtained through fraud, specifically by falsely alleging possession of the lands. They relied on the case of Anuran vs. Aquino to support their claim that such fraud warrants annulment. The Supreme Court, however, found the alleged fraud to be intrinsic, relating to matters presented and considered in the prior adjudication, and thus not a valid ground for annulling a final judgment. The Court affirmed the dismissal, holding that the complaint did not state a cause of action sufficient to invalidate the previous judgment, and also noted that a prior forcible entry case decision, even if existing, would not bar the quiet title action or be conclusive on ownership.
Issue(s)
Whether the alleged fraudulent misrepresentation of possession in the prior case constitutes extrinsic fraud sufficient to annul the judgment. Whether the doctrine of res judicata bars the annulment of the judgment.
Ruling
The Supreme Court affirmed the dismissal of the complaint to annul the judgment. The Court held that the alleged fraud was intrinsic, not extrinsic, and therefore not a ground for annulment. While res judicata might not technically apply to an action seeking to annul a judgment, the complaint was dismissed for failure to state a cause of action sufficient to invalidate the previous final judgment.
Ratio Decidendi
On the issue of extrinsic fraud: The Court clarified the distinction between extrinsic and intrinsic fraud. Extrinsic fraud involves fraud in the means whereby the judgment was procured, such as collusion or preventing a party from presenting their case. Intrinsic fraud, on the other hand, includes false testimony, fraudulent instruments, or any fraudulent matter presented and considered in rendering the judgment. The plaintiffs-appellants' allegation that the defendants-appellees knowingly made false claims of possession in the prior case, which were considered in rendering the judgment, falls under intrinsic fraud. Such allegations, even if true, do not constitute a ground for annulling a judgment. The Court cited Padilla vs. Jordan, which held that a contention of obtaining a judgment by pretending ownership is intrinsic fraud. On the issue of res judicata: The Court acknowledged that technically, the doctrine of res judicata might not be invoked in an action specifically filed to annul a prior judgment. However, this technicality did not prevent the dismissal of the complaint. The dismissal was proper because the complaint, on its face, did not state a cause of action sufficient to invalidate the previous final judgment. The Court reiterated that litigations must end, and not every fraud can be a ground to annul a judgment. The Court also addressed the argument regarding a prior forcible entry case, noting that its decision was not on record and that a forcible entry decision only pertains to possession and does not bar actions concerning ownership.
Main Doctrine
Allegations of perjury or false testimony in a prior case constitute intrinsic fraud, which is not a ground for annulling a judgment, as opposed to extrinsic fraud which pertains to fraud in the means whereby the judgment was procured.