Estrellado v. Francisco
REITERATIONFacts
The Antecedents: The underlying dispute involved three adjacent parcels of land in Davao City, originally owned by related families, the Estrellados and the Barredos. These families sold portions of their land to Dr. Jovito S. Francisco, the predecessor-in-interest of the respondents (collectively referred to as the Franciscos). The core of the dispute centered on whether the larger portions of these lands were also sold to Dr. Francisco. The Franciscos initiated three forcible entry cases against the Estrellados concerning these larger parcels, asserting ownership based on alleged sales, while the Estrellados denied selling these portions and claimed prior possession. Procedural History: The Municipal Trial Court in Cities (MTCC) ruled in favor of the Franciscos in the forcible entry cases, ordering the Estrellados to vacate the properties. This decision was affirmed by the Regional Trial Court (RTC) and subsequently by the Court of Appeals (CA). The Estrellados' appeals to the CA were dismissed, and the decisions became final and executory, leading to a writ of execution. Subsequently, the heirs of the Barredos filed an accion reinvindicatoria and action for quieting of title, asserting ownership over one of the parcels. The RTC ruled against them, but the CA reversed this decision, declaring the Barredo heirs as the lawful owners. Separately, some Estrellado heirs filed a petition for annulment of the MTCC judgments in the RTC, alleging extrinsic fraud and lack of jurisdiction. The RTC dismissed this petition, finding it barred by res judicata and that the petitioners were guilty of forum-shopping. The Petition: The consolidated appeals before the Supreme Court consist of G.R. No. 164482, where petitioners (Estrellado heirs) challenge the RTC's dismissal of their petition for annulment of the MTCC judgments, arguing they were not parties to the original forcible entry cases and thus not bound by the judgments. They sought annulment based on alleged extrinsic fraud and lack of jurisdiction. The second appeal, G.R. No. 211320, involves petitioners (Barredo heirs) who are challenging the CA's reversal of the RTC decision in their accion reinvindicatoria, asserting their ownership of a specific parcel of land. The Supreme Court is asked to determine the validity of the annulment petition and the ownership claims over the disputed properties.
Issue(s)
Whether the RTC correctly dismissed the petition for annulment of judgment in G.R. No. 164482 and whether the Estrellados, as successors-in-interest, are bound by the final and executory judgments in the forcible entry cases despite not being expressly impleaded. Whether the alleged extrinsic fraud committed by the Estrellados' counsel justifies the annulment of judgment. Whether the MTCC had jurisdiction over the forcible entry cases. Whether the CA erred in reversing the RTC decision in G.R. No. 211320 and declaring the heirs of Spouses Alipio and Vivina Barredo as the lawful owners and possessors of the property covered by TCT No. T-19930. Whether the sale of the parcel of land covered by TCT No. T-19930 by the late Spouses Alipio and Vivina Barredo to Dr. Jovito S. Francisco was valid and enforceable.
Ruling
In G.R. No. 164482, the Court AFFIRMS the decision of the RTC dismissing the petition for annulment of judgment. In G.R. No. 211320, the Court REVERSES and SETS ASIDE the decision of the CA and REINSTATES the decision of the RTC.
Ratio Decidendi
On the dismissal of the petition for annulment of judgment (G.R. No. 164482) and whether Estrellados are bound by the judgments (G.R. No. 164482): The RTC correctly dismissed the petition for annulment of judgment. A petition for annulment of judgment is an exceptional remedy available only when other remedies are wanting and when the judgment sought to be annulled was rendered without jurisdiction or through extrinsic fraud. In this case, the judgments of the MTCC had already been affirmed by the RTC and the CA, and had become final and executory. The Estrellados, or their predecessors-in-interest, had availed themselves of the remedy of appeal, thus precluding them from resorting to an annulment of judgment. The Estrellados, as heirs and successors-in-interest, are bound by the final and executory judgments in the forcible entry cases, notwithstanding that they were not expressly impleaded as defendants. This is due to privity with their predecessors-in-interest. The Court reiterated that a judgment in an ejectment suit, even if in personam, can be enforced against a non-party who is a trespasser, squatter, agent of the defendant, guest or occupant with permission, transferee pendente lite, sublessee, co-lessee, or a member of the family, relative, or privy of the defendant. The Estrellados fall under the category of privies, having succeeded to the rights and obligations of the original defendants. On whether the alleged extrinsic fraud committed by the Estrellados' counsel justifies the annulment of judgment: The alleged extrinsic fraud, attributed to their own counsel, did not qualify as extrinsic fraud under Rule 47 of the Rules of Court, as it did not prevent them from having a trial or presenting their entire case. The Franciscos, as the prevailing parties, were not involved in this alleged fraud. On whether the MTCC had jurisdiction over the forcible entry cases: The MTCC had jurisdiction over the forcible entry cases, as the averments of the Franciscos were resolved and affirmed by higher courts. On the CA's reversal of the RTC decision in G.R. No. 211320: The CA erred in reversing the RTC decision and declaring the heirs of Spouses Alipio and Vivina Barredo as the lawful owners. While adjudication of ownership in ejectment cases is provisional, the RTC in the accion reinvindicatoria case had the opportunity to determine ownership. The Franciscos presented documentary evidence, namely a certification dated June 10, 1970, and a receipt dated June 13, 1970, signed by the late Spouses Alipio and Vivina Barredo, which clearly indicated the sale of their parcel of land to Dr. Jovito S. Francisco. These documents, though not a formal deed of sale, were sufficient to establish a contract of sale enforceable under the Statute of Frauds, as they were in writing and signed by the party charged. The non-observance of the form prescribed by Article 1358 of the Civil Code did not invalidate the sale. On the validity and enforceability of the sale (G.R. No. 211320): The sale of the parcel of land by the late Spouses Alipio and Vivina Barredo to Dr. Jovito S. Francisco was valid and enforceable. The certification and receipt signed by the sellers constituted sufficient written evidence of the sale of real property under the Statute of Frauds. Article 1403(2) of the Civil Code requires such agreements to be in writing and subscribed by the party charged. The documents presented met this requirement. The absence of a formal deed of sale acknowledged before a notary public, as contemplated by Article 1358(1) of the Civil Code, did not render the sale invalid, as this formality is for convenience and not essential to the validity or enforceability of the sale. Possession of the owner's duplicate copy of the Transfer Certificate of Title (TCT) by the respondents did not automatically equate to ownership, as the TCT is merely evidence of title and registration is not a mode of acquiring ownership.
Main Doctrine
A petition for annulment of judgment is an exceptional remedy available only when other remedies are wanting and when the judgment was rendered without jurisdiction or through extrinsic fraud. It cannot be used to relitigate issues already passed upon and affirmed by higher courts, nor can it be availed of by parties who had already appealed the decision. Furthermore, a judgment in an ejectment case, while primarily concerning possession, can bind successors-in-interest or privies of the original parties.