G.R. No. L-28109 December 28, 1973
Mateo Tolentino, et al., plaintiffs-appellants, vs. Matea Grospe, et al., defendants-appellees.

FACTS

The plaintiffs-appellants, Mateo Tolentino et al., filed an action to annul a prior judgment rendered in Civil Case No. 3698 by the Court of First Instance of Nueva Ecija. The prior case involved a land dispute over Lot No. 419, and the judgment was based on a stipulation of facts entered into by the parties’ counsel. The appellants contended that this judgment was null and void because they themselves did not personally sign the stipulation of facts, claiming their former counsel lacked specific authorization to bind them to such an agreement. They admitted the decision in Case No. 3698 had long become final and executory, with a writ of execution already issued.
The trial court dismissed the annulment case. It found that the appellants had previously filed a motion to set aside the judgment in Case No. 3698 on the same grounds, which motion was denied. The appellants did not appeal that order of denial. The lower court held that the proper remedy against the judgment was a timely appeal, not an independent action for annulment, especially absent any allegation of extrinsic fraud or lack of jurisdiction by the court that rendered the challenged decision.

ISSUE

Whether the trial court correctly dismissed the independent action for annulment of judgment.

RULING

Yes, the Supreme Court affirmed the dismissal. The legal logic is anchored on the finality of judgments and the limited grounds for a collateral attack. A judgment that has become final and executory is immutable and unalterable. It can only be assailed collaterally on grounds of lack of jurisdiction over the subject matter or parties, or due to extrinsic fraud. The appellants’ claim—that their counsel’s unauthorized execution of a stipulation of facts invalidated the judgment—does not constitute a jurisdictional defect. The court in Case No. 3698 unquestionably had jurisdiction over the parties and the subject matter.
The alleged defect pertains to the evidence or the agreement underlying the decision, not to the court’s authority to render it. The proper remedy for such an alleged irregularity was to seek reconsideration or to appeal the judgment before it became final. The appellants did file a motion to set aside, but upon its denial, they forfeited their right by not appealing. They cannot now resurrect the issue through a separate action, as this would undermine judicial stability and the doctrine of finality. The Court also noted the stipulation was not a compromise agreement but a factual submission to abbreviate trial, and its contents were substantiated by documentary evidence, which the appellants did not even contest on the merits. The dismissal for lack of cause of action was therefore proper.