GR L 1696; (September, 1949) (Digest)
G.R. No. L-1696; September 30, 1949
ANACLETO DE ALMEDA, ET AL., plaintiffs-appellants, vs. ADRIANO F. CRUZ, defendant-appellee.
FACTS
Plaintiffs Anacleto de Almeda and his wife, previously plaintiffs in Civil Case No. 7485, sought to annul the judgment in that case. In the original case, they sued for recovery of possession of land they purchased from Esteban Zarraga, claiming defendant Adriano F. Cruz was merely a lessee. Cruz defended, asserting ownership of one-half of the land by inheritance and adverse possession, and sought reconveyance. The Court of First Instance of Laguna ruled in favor of Cruz, declaring him the exclusive owner of one-half of the property, ordering reconveyance, and awarding damages. The plaintiffs’ appeal was dismissed for failure to file a brief. Subsequently, the plaintiffs filed the present action to annul the judgment, alleging two grounds: (1) that the judgment was procured by fraud because Cruz concealed that he had already sold his interest to Zarraga and received full payment; and (2) that during the trial, Cruz used his connections with Japanese authorities to prevent the plaintiffs and their witnesses from testifying about the true nature of the transaction. The trial court dismissed the complaint on a motion to dismiss.
ISSUE
Whether the complaint states a valid cause of action for annulment of judgment based on alleged extrinsic fraud.
RULING
No. The Supreme Court affirmed the dismissal of the complaint. The Court held that the allegations of fraud were vague and insufficient. The alleged concealment by Cruz of the prior sale was a matter that could and should have been raised in the original trial, as it pertained to the merits of the ownership claim. The allegation of interference by Japanese authorities was deemed implausible, as the plaintiffs themselves initiated the suit and could have sought alternative means to present testimony, such as depositions, or could have moved for dismissal or postponement. The Court emphasized the policy of finality of judgments and placed a heavier burden on a plaintiff seeking to annul a judgment they themselves previously invoked. The complaint failed to make a concrete and probable showing of extrinsic fraud that would justify nullifying the prior judgment.
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