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ANTONIO DEMETRIOU v. CA

FACTS:

The petitioners are co-owners of Lot No. 7651-A in Tabaco, Albay and they acquired two-thirds of the property through deeds of absolute sale. At the time of the sale, there was a ten-year lease contract over the property which was scheduled to expire. After the expiration of the lease contract, the father of the petitioners went to the Register of Deeds to register the sale and obtain a new title, but discovered that a new second owner's duplicate copy of the title had been issued to the private respondent. Upon further investigation, it was revealed that the private respondent had falsely alleged that the owner's duplicate copy of the title was lost and had been issued a new copy based on this false representation. As a result, the petitioners filed an action in the Court of Appeals seeking to annul the decision of the Regional Trial Court, which ordered the Register of Deeds to issue a new owner's duplicate certificate of title to the private respondent. However, the Court of Appeals denied their petition, stating that the fraud alleged was not extrinsic fraud but rather intrinsic fraud, which did not justify setting aside the final decision of the trial court. Dissatisfied with the decision of the Court of Appeals, the petitioners filed a petition for review.

ISSUES:

  1. Whether the alleged fraud in the issuance of a new owner's duplicate certificate of title constitutes extrinsic fraud.

  2. Whether the fraud alleged justifies setting aside the final decision of the trial court.

RULING:

  1. The Court of Appeals denied the petition for annulment of judgment on the ground that the fraud alleged was not extrinsic fraud but only intrinsic fraud.

  2. The Court of Appeals ruled that the fraud alleged, even if proven, does not justify setting aside the final decision of the trial court.

PRINCIPLES:

  • Extrinsic fraud refers to fraudulent acts committed outside the trial of the case, which prevents a party from presenting his case or prevents the court from hearing and fully determining the issue presented to it.

  • Intrinsic fraud, on the other hand, refers to fraudulent acts committed during the trial, which prevents a party from presenting his case fully or effectively.

  • Extrinsic fraud is a ground for the annulment of judgment, while intrinsic fraud is not.

  • To set aside a final decision of a trial court, the fraud alleged must be extrinsic in nature. Intrinsic fraud is not a valid ground for setting aside a final decision.