Capacete v. Baroro
REITERATIONFacts
The Antecedents: Since 1956, petitioners Teodora and Rodolfo Capacete have possessed a parcel of land, Lot 88, Cad No. 455-D, in Cabuyao, Laguna. Respondent Venancia Baroro applied for a free patent for this land in 1975, which the petitioners opposed. In 1977, Baroro and her husband filed an unlawful detainer case against the Capacetes, claiming their possession was by mere tolerance. The Capacetes asserted they had bought the land in 1956. The Municipal Trial Court (MTC) ruled in favor of Baroro in 1989, but the Capacetes' appeal was dismissed for being filed late. Procedural History: The Capacetes subsequently filed an accion reinvindicatoria, annulment of decision, and quieting of title case with the Regional Trial Court (RTC) in 1990, claiming they purchased the land in 1956. The RTC ruled in favor of Baroro in 1998, declaring her the owner and ordering the Capacetes to vacate and pay damages. The Capacetes' appeal to the Court of Appeals (CA) was deemed abandoned due to their counsel's failure to pay docket fees. They then filed a complaint for injunction with another RTC branch, which was dismissed for interfering with another branch's judgment. A petition for certiorari with this Court was also dismissed for failure to submit required documents. In 2001, Baroro moved for execution of the RTC judgment. The Capacetes then filed a petition with the CA to annul the RTC judgment based on extrinsic fraud, which the CA dismissed in November 2001, finding the grounds insufficient under Rule 47. The CA denied their motion for reconsideration in July 2002. The Petition: The petitioners are now before this Court via a petition for review on certiorari under Rule 45, assailing the CA's resolutions. Their sole assignment of error is that the CA erred in not ruling that the RTC lacked jurisdiction to issue the writ of execution in Civil Case No. B-3433, arguing such a writ should only be issued by the MTC in Civil Case No. 89. They contend the RTC decision and consequential orders are void due to this alleged lack of jurisdiction. Additionally, they claim they were not furnished a copy of the motion for execution, violating procedural rules. The Supreme Court found no merit in the petition, emphasizing that the RTC had jurisdiction over the accion reinvindicatoria and quieting of title claims, which empowered it to issue the writ of execution and order ejectment. The Court also noted that records showed proper notice and hearing for the motion for execution.
Issue(s)
Whether the Court of Appeals erred in not ruling that the Regional Trial Court has no jurisdiction to issue the writ of execution in Civil Case No. B-3433. Whether the RTC decision in Civil Case No. B-3433 and the writ of execution must be annulled due to the RTC's alleged lack of jurisdiction. Whether the petitioners were denied due process for not being furnished a copy of the motion for execution and for lack of a hearing.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not err in dismissing the petition for annulment of judgment. The Regional Trial Court had jurisdiction to issue the writ of execution in Civil Case No. B-3433.
Ratio Decidendi
On the issue of the RTC's jurisdiction to issue the writ of execution: The Court reiterated that a petition for annulment of judgment under Rule 47 of the Rules of Civil Procedure can only be based on extrinsic fraud or lack of jurisdiction. The petitioners' claim that the RTC lacked jurisdiction to issue the writ of execution in Civil Case No. B-3433 does not fall under lack of jurisdiction over the person or the subject matter. The RTC had duly acquired jurisdiction over the petitioners when they filed their complaint, and the subject matter of their claims (accion reinvindicatoria, annulment of MTC decision, quieting of title) were within its cognizance. Furthermore, the RTC, having decided the ownership of the land in an accion reinvindicatoria, had the inherent power to issue the necessary writs, including a writ of execution and ejectment, to enforce its judgment. The contention that only the MTC could order ejectment was dismissed as a means to delay the execution of a final and executory judgment. On the issue of annulment of judgment due to lack of jurisdiction: The Court clarified that the alleged lack of jurisdiction of the RTC in issuing the writ of execution was not a lack of jurisdiction over the person or the subject matter. The RTC had jurisdiction over the parties and the subject matter of the case, which included accion reinvindicatoria and quieting of title, not merely reviewing the MTC decision. Therefore, the RTC's power to issue the writ of execution was well within its authority to enforce its judgment on ownership and possession. On the issue of denial of due process: The Court found the petitioners' contention that they were not furnished a copy of the motion for execution and were denied a hearing to be baseless. The records showed that a copy of the motion for execution was served to the petitioners' counsel of record, and a hearing was conducted. Thus, the petitioners had the opportunity to be notified and to be heard, refuting their claim of denial of due process.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Civil Procedure can only be based on the grounds of extrinsic fraud or lack of jurisdiction. Allegations of lack of due process or that the trial court lacked jurisdiction to issue a writ of execution, when the court had already acquired jurisdiction over the person and the subject matter, do not constitute grounds for annulment.