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    1. The Supreme Court ruled that a final judgment can be annulled due to lack of jurisdiction over indispensable parties or denial of due process, not just extrinsic fraud. 2. Only evidence found in the records of the original case can be used to justify annulment of a judgment for lack of jurisdiction, not extraneous matters. 3. An independent action before the Court of Appeals is allowed to annul a trial court decision affirmed by higher courts if it is void for lack of jurisdiction over indispensable parties, rather than only allowing intervention in the court of origin.

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    Arcelona v CA

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    1. The Supreme Court ruled that a final judgment can be annulled due to lack of jurisdiction over indispensable parties or denial of due process, not just extrinsic fraud. 2. Only evidence found in the records of the original case can be used to justify annulment of a judgment for lack of jurisdiction, not extraneous matters. 3. An independent action before the Court of Appeals is allowed to annul a trial court decision affirmed by higher courts if it is void for lack of jurisdiction over indispensable parties, rather than only allowing intervention in the court of origin.

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    278 views1 page

    Arcelona V CA

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    1. The Supreme Court ruled that a final judgment can be annulled due to lack of jurisdiction over indispensable parties or denial of due process, not just extrinsic fraud. 2. Only evidence found in the records of the original case can be used to justify annulment of a judgment for lack of jurisdiction, not extraneous matters. 3. An independent action before the Court of Appeals is allowed to annul a trial court decision affirmed by higher courts if it is void for lack of jurisdiction over indispensable parties, rather than only allowing intervention in the court of origin.

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    ARCELONA V CA Doctrine: SC stressed that when the IAC and the SC affirmed the RTC decision, they were

    not given the occasion to rule on the issue of the TCs jurisdiction over the persons of the indispensable parties as they are limited by the issues raised before them. Thus substantial justice requires that SC be allowed to nullify the RTC decision for lack of jurisdiction even if previously affirmed by them. PANGANIBAN, J.: FACTS: 1. 2. 3. 4. 5. 6. 7. 8. 9. Petitioners are co-owners pro-indiviso of a fishpond which they inherited from their deceased parents. 6 siblings are co-owners some of which live abroad (3 in the Philippines and 3 abroad). A lease contract was executed over the fishpond between Tandoc and Olanday (siblings in the Philippines). Upon termination of the lease, the premises were surrendered to Olanday by the caretaker of the lessee. Three days after, respondent Farnacio instituted a case for peaceful possession against Olanday intended to maintain himself as tenant of the fishpond. The RTC rendered a decision in favor of Farnacio. Olanday then elevated the decision to the IAC which affirmed with modification the RTC decision. On appeal, the SC sustained the IAC decision after remand of the case to the court of origin, private respondent was placed in possession of the entire property. Petitioners filed with the CA a petition for annulment of judgment against private respondent and the implementing sheriff. Dissatisfied with the CA resolution, a petition for review was filed with the SC. Note: the 3 Arcelona sisters who were abroad were not impleaded as indispensable parties, only the other sisters (Olanday) were impleaded.

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    ISSUES: (1) May a final judgment be annulled on the ground of lack of jurisdiction (over the subject matter and/or over the person of indispensable parties) and denial of due process, aside from extrinsic fraud?-YES (2) May extraneous matters, not found in the records of the original case, be used in voiding or defending the validity of such final judgment?-NO (3) Will an independent action for annulment of the decision of the regional trial court (which was affirmed both by the CA and the SC) filed before the CA prosper, or is intervention before the court of origin the only remedy? YES RATIO:

    Fraud is not only the ground to attack a final and executory judgment. According to the SC in the Makabingkil case there are three ways to attack a judgment. a. First, by petition for relief under R38 when judgment has been taken against the party through fraud, accident, mistake or excusable negligence which case the petition must be filed w/in 60d after petitioner learns of judgment but not more than 6 months after entry of judgment. b. Second is direct action to annul and enjoin the enforcement of the judgment on the ground of extrinsic fraud. c. Third is either a direct action, as certiorari, or by collateral attack to annul a judgment that is void upon its face or void by virtue of its own recitals. Thus, Macabingkildid not preclude the setting aside of a decision that is patently void where mere inspection of the judgment is enough to demonstrate its nullity on grounds of want of jurisdiction or non-compliance with due process of law. SC stressed that when the IAC and the SC affirmed the RTC decision, they were not given the occasion to rule on the issue of the TCs jurisdiction over the persons of the indispensable parties as they are limited by the issues raised before them. Thus substantial justice requires that SC be allowed to nullify the RTC decision for lack of jurisdiction even if previously affirmed by them. On the second issue, SC held that the CA erred in annulling or declaring null the decision in considering extraneous matters. In an action to declare a judgment void because of lack of jurisdiction over the parties or subject matter, only evidence found in the records of the case can justify the annulment of the said judgment. On the third issue, SC stated that intervention is not the only remedy to assail a void final judgment. A direct action is available in assailing final judgments grounded on extrinsic fraud, while a direct or a collateral action may be used to show lack of jurisdiction. In any event, jurisprudence upholds the soundness of an independent action to declare as null and void a judgment rendered without jurisdiction as in this case.

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