Carillo v. Court of Appeals
REITERATIONFacts
The Antecedents: Maria Gonzales filed a complaint for specific performance against spouses Priscilla and Jose Manio, seeking the execution of a deed of sale for a property she allegedly bought from Priscilla, who acted as attorney-in-fact for her son Aristotle, the owner. Gonzales paid a downpayment and agreed to pay the balance within three months after the execution of the deed of sale. For failure to file an Answer, the Manios were declared in default, and the RTC ruled in favor of Gonzales, ordering the execution of the deed of sale and awarding damages. Procedural History: Gonzales deposited the balance and later filed a motion for execution, which she withdrew. After the decision was served on Priscilla, it became final and executory due to no appeal. However, a writ of execution was not served as the defendants could not be located. Gonzales filed motions to have the Clerk of Court execute the deed and to withdraw the cash deposit to offset damages, which were granted. Subsequently, Gonzales filed a petition to nullify the Owner's Duplicate Certificate of Title No. 16658 and to issue a new certificate in her name, which the RTC granted. Respondents Maria Paz and Rosalina Dabon, claiming to have bought the lot from Aristotle Manio, filed a petition for annulment of judgment and orders with the Court of Appeals (CA), alleging lack of jurisdiction and fraudulent deprivation of due process. The CA issued a restraining order and later annulled the RTC's judgment and cancelled the new title issued to Gonzales. The Petition: Gonzales filed a petition for certiorari with the Supreme Court, assailing the CA's decision, arguing that the sale to her was valid, she was in good faith, the doctrine of double sale should apply, and the Dabons had no right to file the suit.
Issue(s)
Whether the Court of Appeals erred in declaring the sale of the land to petitioner Maria Gonzales by Priscilla Manio invalid, and whether the doctrine of double sale applies. Whether there was a basis to annul the judgment of the RTC. Whether the respondents Maria Paz Dabon and Rosalina Dabon could file the action for annulment of judgment, and the effect of failing to implead Aristotle Manio.
Ruling
The petition is DENIED for lack of merit. The assailed Decision dated February 22, 1995 of the Court of Appeals in CA-G.R. SP No. 23687, is AFFIRMED.
Ratio Decidendi
On the validity of the sale to Maria Gonzales and the applicability of the doctrine of double sale: The Supreme Court held that the doctrine of double sale under Article 1544 of the Civil Code was not relevant in the present petition for review. The action for annulment of judgment under Rule 47 of the Rules of Court does not involve the merits of the final order of the trial court, and the issue of ownership is outside the scope of the present petition. The extraneous evidence presented to the appellate court was only to prove extrinsic fraud and could not be used to supplant the evidence in the records of the specific performance case. Therefore, the issue of ownership could not be addressed in this petition. On the basis for annulment of the RTC judgment: The Supreme Court affirmed the Court of Appeals' finding that there was sufficient basis to annul the judgment of the RTC. The Court of Appeals found indices of fraud, including the deliberate exclusion of the Dabons as parties despite knowledge of their alleged purchase, the suspicious midnight service of the Sheriff's Return, and the lack of notice to parties in interest in the petition for cancellation of title. These acts, particularly the failure to notify parties entitled to notice, constitute extrinsic fraud, which is a ground for annulment of judgment. On whether the Dabons could file the action for annulment of judgment and the effect of failing to implead Aristotle Manio: The Supreme Court ruled that a person need not be a party to the judgment sought to be annulled to file a petition for annulment. It is sufficient that they can prove their allegation that the judgment was obtained by fraud or collusion and that they would be adversely affected thereby. In this case, the Dabons, claiming to be buyers and possessors of the contested land, had standing to file the petition for annulment of judgment because the judgment in Civil Case No. 2647, if not annulled, would adversely affect their ownership. The Court also emphasized that the failure to implead Aristotle Manio, the actual owner, as an indispensable party in the original case rendered all proceedings null and void for lack of jurisdiction over the real party in interest.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court is an independent action that can be filed by a party not privy to the original case, provided they can prove that the judgment was obtained by extrinsic fraud or that the court lacked jurisdiction over the real parties in interest, and that they would be adversely affected thereby. The failure to implead indispensable parties renders all subsequent proceedings null and void.