Conde v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership and possession of a parcel of land. Marcelo Gutierrez filed an original complaint for recovery of possession in 1950. After extensive proceedings, the Regional Trial Court initially dismissed Gutierrez's complaint and ordered him to pay costs. However, the Court of Appeals reversed this decision, ordering the appellees (now petitioners) and/or their successors-in-interest to deliver the property's ownership and possession to Marcelo Gutierrez. This appellate decision became final and executory. Procedural History: Following the finality of the Court of Appeals' decision, the petitioners filed an action to annul that judgment in the Regional Trial Court of Capas, Tarlac, alleging fraud by Marcelo Gutierrez in establishing his filiation and subsequent ownership. The Regional Trial Court dismissed this complaint for lack of jurisdiction to annul a Court of Appeals judgment. The petitioners' motion for reconsideration was denied. They then filed a petition for certiorari, mandamus, and injunction with the Intermediate Appellate Court, which also dismissed the petition, reiterating that a Regional Trial Court lacks jurisdiction to annul a judgment of the appellate court and that only the Supreme Court can review such decisions. This Court initially remanded the case to the Intermediate Appellate Court for a decision on the merits. Subsequently, the Intermediate Appellate Court dismissed the petition again, first for lack of jurisdiction and then, on the merits, finding the alleged fraud to be intrinsic, not extrinsic. The Petition: The petitioners have elevated the case to this Court, seeking a review of the Intermediate Appellate Court's decision. They contend that the appellate court erred in dismissing their action for annulment of judgment. The core of their argument revolves around the alleged fraud employed by Marcelo Gutierrez in obtaining the appellate court's favorable judgment, which they claim prevented a fair trial. The petitioners argue that this fraud was extrinsic in nature, thereby warranting annulment. However, this Court finds that the alleged fraud, relating to fabricated evidence or false testimony, is intrinsic and not extrinsic, and therefore, does not provide a basis for annulling the judgment. The petition is dismissed for lack of merit.
Issue(s)
Whether the Regional Trial Court has jurisdiction to annul a judgment rendered by the Court of Appeals. Whether the alleged fraud employed by the respondent in obtaining the Court of Appeals judgment was extrinsic or intrinsic. Whether the Supreme Court, having remanded the case to the Court of Appeals for decision on the merits, could still review the appellate court's subsequent decision on jurisdiction and merits.
Ruling
The petition is dismissed for lack of merit. The respondent's counsel is fined P500.00 for failure to file a comment as ordered.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court to annul a Court of Appeals judgment: The Court reiterated the established rule that a Regional Trial Court is without jurisdiction to annul a judgment rendered by the Court of Appeals. This power is vested solely in the Supreme Court. The Judiciary Reorganization Act of 1980 (B.P. Blg. 129) grants the Court of Appeals exclusive jurisdiction over actions for annulment of judgments of Regional Trial Courts, but it does not grant lower courts the power to annul judgments of higher courts. The Court emphasized that the Supreme Court speaks with finality on legal matters, and lower courts are bound to defer to its pronouncements. The initial remand to the IAC was for it to decide on the merits, and its subsequent dismissal on jurisdictional grounds was a misinterpretation of its role and the Supreme Court's directive. On the nature of the alleged fraud: The Court affirmed the appellate court's finding that the alleged fraud was intrinsic, not extrinsic. Extrinsic fraud is defined as a fraudulent scheme that prevents a party from having their day in court or presenting their case, operating on matters outside the judgment itself, such as preventing a party from appearing or presenting evidence. Intrinsic fraud, on the other hand, involves acts committed during the trial, such as the use of forged instruments or perjured testimony, which do not prevent a party from presenting their case but may prevent a fair determination. The petitioners' allegation that Marcelo Gutierrez manufactured documents to appear as the rightful heir was classified as intrinsic fraud, as it pertained to the evidence presented during the trial and did not prevent the petitioners from presenting their side. On the Supreme Court's review of the appellate court's decision: The Court clarified that it is not its function to re-analyze or weigh evidence, as its jurisdiction is limited to errors of law. While the case was remanded to the IAC for decision on the merits, the IAC's subsequent decision, which delved into jurisdictional issues and factual findings regarding fraud, was still subject to review by the Supreme Court. However, the Court found that the IAC's conclusion on the intrinsic nature of the fraud was correct, rendering the petition without merit. The Court also noted that the IAC's hesitation to act on the remanded case was unwarranted, given the clear directive from the Supreme Court.
Main Doctrine
A Regional Trial Court has no jurisdiction to annul a judgment of the Court of Appeals. Only the Supreme Court is empowered to review and annul judgments of the Court of Appeals. Fraud that consists in the use of forged instruments or perjured testimony, or that does not prevent a party from having a trial or presenting his case, is intrinsic fraud and is not a ground for annulment of judgment.