Sps. Atienza v. The Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioners, Spouses Bernardo V. Atienza and Eufrocina M. Atienza, obtained a housing loan from the Government Service Insurance System (GSIS) in 1963, secured by a mortgage on two parcels of land. Despite making payments totaling P185,000.00 to forestall foreclosure, GSIS proceeded with an auction sale where it was the highest bidder. New titles were issued in GSIS's name, and the petitioners' subsequent offer to repurchase the properties was denied. 2. Procedural History: The petitioners filed multiple injunction suits against GSIS, which were dismissed by various Regional Trial Courts (RTCs) on grounds of improper venue, litis pendentia, and res judicata. One of these dismissals (Civil Case No. 93-060) was initially appealed to the Court of Appeals (CA G.R. No. 44937) but was withdrawn. Subsequently, the petitioners filed a complaint for annulment of sale (Civil Case No. 94-2342) before the RTC of Makati, which was dismissed by the RTC for forum shopping. This dismissal was affirmed by the Court of Appeals (CA G.R. SP No. 38198) which found the petitioners had used the wrong remedy (certiorari instead of a petition for review). The Supreme Court (G.R. No. 125268) denied the subsequent petition for review on certiorari, citing lateness and lack of reversible error. 3. The Petition: The petitioners filed the present petition for review on certiorari, arguing that the Court of Appeals erred in holding that there was no extrinsic or collateral fraud, and that the dismissal of the prior injunction suits did not constitute res judicata. They contend that the order of dismissal was procured by GSIS through fraud and misrepresentation, preventing them from presenting their case. The Supreme Court, however, found the petition to be without merit, noting that the case had already been decided with finality by the Court and that the principle of judicial finality requires an end to litigation.
Issue(s)
Whether the Court of Appeals erred in holding that there was no extrinsic or collateral fraud, and whether the petition for annulment of judgment was the proper remedy. Whether the Court of Appeals erred in holding that the dismissal of the injunction suits constituted res judicata, thereby barring the annulment of sale case.
Ruling
The petition is not meritorious. The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals. The Court held that the case had already been decided with finality by the Supreme Court in a previous petition for review on certiorari (G.R. No. 125268), which was denied for being filed one day late and for failure to show reversible error. The Court reiterated the principle that litigation must come to an end and that a litigant should not be granted an unbridled license to come back for another try after a valid final judgment.
Ratio Decidendi
On the propriety of the petition for annulment of judgment and the alleged extrinsic fraud: The Court found that the present case had already been decided with finality by the Supreme Court in G.R. No. 125268. The previous petition for review on certiorari was denied for being filed one day late and for failure to show any reversible error. The Court emphasized the fundamental principle that every litigation must come to an end, and a litigant should not be granted an unbridled license to relitigate a case once a valid final judgment has been rendered. The principle of immutability of judgments bars further proceedings once a judgment becomes final and executory. The Court also noted that the Court of Appeals correctly identified that the appropriate remedy after the denial of the motion for reconsideration was a petition for review on certiorari, not a petition for certiorari. By failing to file the correct remedy on time, the petitioners lost their recourse, and the assailed orders became final and executory. The Court of Appeals also correctly defined extrinsic fraud, which requires proof that the prevailing party committed fraudulent acts outside the trial that prevented the defeated party from presenting their case. The alleged fraud in this case did not meet this standard. On the issue of res judicata: The Court did not directly address the merits of the res judicata argument in relation to the injunction suits in its final resolution. However, the dismissal of the present petition on the ground of finality of the previous Supreme Court decision effectively renders the issue of res judicata moot. The prior dismissals of the injunction cases were already affirmed by the Supreme Court's denial of the petition for review on certiorari in G.R. No. 125268. The principle of res judicata dictates that once a matter has been litigated and decided by a competent court, it cannot be relitigated. The Supreme Court's denial of the petition for review on certiorari in G.R. No. 125268, which involved the same parties and issues concerning the dismissal of the annulment of sale case, meant that the dismissal order had attained finality. Therefore, any attempt to reopen the case through a petition for annulment of judgment, based on grounds that were either already passed upon or could have been raised in the prior proceedings, would be barred.
Main Doctrine
A petition for annulment of judgment is a special civil action that may be availed of only when the ordinary remedies of new trial, appeal, or petition for relief are no longer available, and it is only then that the law allows an exception to the principle of immutability of judgments. Furthermore, a petition for annulment of judgment based on extrinsic fraud requires proof that the prevailing party committed fraudulent acts outside of the trial of the case, which prevented the defeated party from presenting their case.