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Valentin Fraginal et al. vs. Heirs of Toribia Belmonte Paranal G.R. No.

150207 FACTS: The heirs of Toribia Belmonte Paraal filed with the Office of the Pro incial !"rarian Reform !d#$dicator %P!R!&' of the &e(artment of !"rarian Reform !d#$dication Board %&!R!B') *amarines +$r) a *om(laint for Termination of Tenanc, Relationshi() -#ectment) and *ollection of !rrear Rentals and &ama"es a"ainst .alentin /ra"inal et al. /ra"inal) et al. filed an !nswer 0$estionin" the #$risdiction of the P!R!& on the "ro$nd that the, are not tenants of the 1eirs of Toribia Paraal) for the land the, are tillin" is a 1.12034hectare ($blic a"ric$lt$ral land within the e5cl$si e #$risdiction of the &e(artment of -n ironment and Nat$ral Reso$rces. The P!R!& iss$ed a &ecision on October 3) 1663 orderin" the e#ectment of /ra"inal) et al. On !(ril 5) 2001) two ,ears from iss$ance of the P!R!& &ecision) /ra"inal) et al. filed with the *! a Petition for !nn$lment of 7$d"ment with Pra,er for 8ss$ance of Preliminar, 8n#$nction and9or Restrainin" Order. The, insisted that the P!R!& &ecision is oid as it was iss$ed witho$t #$risdiction. B$t the *! dismissed the (etition and li:ewise denied the ;otion for Reconsideration. ISSUE: <hether or not R$le 27 of the R$les of *o$rt (ertains onl, to #$d"ment or final orders and resol$tions in ci il actions of the RT*. HELD: +ection 1 of R$le 27 clearl, limits the s$b#ect matter of (etitions for ann$lment to final #$d"ments and orders rendered b, Re"ional Trial *o$rts in ci il actions. /inal #$d"ments or orders of 0$asi4#$dicial trib$nals or administrati e bodies s$ch as the National =abor Relations *ommission) the Omb$dsman) the *i il +er ice *ommission) the Office of the President) and) in this case) the P!R!&) are not s$sce(tible to (etitions for ann$lment $nder R$le 27. +ections 1 and 2 of R$le 27 im(ose strict conditions for reco$rse to it) viz.> +ection 1. Coverage.4 This R$le shall "o ern the ann$lment b, the *o$rt of !((eals of #$d"ments or final orders and resol$tions in ci il actions of Re"ional Trial *o$rts for which the ordinar, remedies of new trial) a((eal) (etition for relief or other a((ro(riate remedies are no lon"er a ailable thro$"h no fa$lt of the (etitioner. +ection 2. Grounds for annulment. ? The ann$lment ma, be based onl, on the "ro$nds of e5trinsic fra$d and lac: of #$risdiction. The Petition for !nn$lment of 7$d"ment filed b, /ra"inal) et al. before the *! failed to meet the fore"oin" conditions. /ra"inal) et al.) co$ld ha e a((ealed to the &!R!B e en witho$t reso$rces or co$nsel. The, co$ld ha e as:ed for e5em(tion from (a,ment of the a((eal fee) as allowed $nder +ection 5) R$le @888. The, co$ld ha e also re0$ested for co$nsel de oficio from amon" &!R law,ers and le"al officers) as (ro ided $nder +ection A) R$le .88. The, a((ear not to ha e needed one) considerin" that the, seem to ha e ade0$atel, fended for themsel es as shown b, the !nswer the, (re(ared) which raised a well4tho$"ht o$t le"al defense. !s it were) the, ne"lected to e5ercise an, of these ri"hts and chose to fritter awa, the remed, still a ailable to them at that time. Their direct reco$rse to the *! thro$"h a (etition for ann$lment of the P!R!& &ecision was therefore ill4fated.

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