FACTS : Federico C. Suntay was married to Cristina Aguinaldo-Suntay, with whom he had one son, Emilio, who predeceased them. Emilio was survived by his children, petitioners Emilio Aguinaldo Cojuangco-Suntay, Jr. and Isabel Aguinaldo Cojuangco-Suntay, among others. After Emilio's death, Federico legally adopted respondents Emilio Suntay III and Nenita Suntay Tañedo. Following Cristina's intestate death, disputes arose over the settlement of her estate, prompting Isabel to file a petition for letters of administration. During the pendency of the administration case, Federico initially executed a will recognizing petitioners as compulsory heirs but later revoked it. After the Supreme Court declared petitioners to be Federico's legitimate grandchildren in a separate case, Federico executed a second will disinheriting them, alleging that their father had repudiated his inheritance and that petitioners were guilty of maltreatment, abandonment, and gross ingratitude. He filed a petition for the probate of the second will before the RTC of La Trinidad, Benguet, which admitted the will to probate, later upheld its intrinsic validity, approved the project of partition in favor of respondents, and issued the corresponding letters testamentary. Petitioners claimed that they were never notified of the probate proceedings and only learned of the probate after the RTC decisions had become final and executory. They thus filed a petition for annulment of judgment before the Court of Appeals, alleging extrinsic fraud, lack of jurisdiction due to defective notice, and deliberate concealment of the proceedings. The CA denied the petition, ruling that petitioners failed to prove non-service of notices, that the proceedings enjoyed the presumption of regularity, and that the action was barred by laches. Aggrieved, petitioners elevated the case to the Supreme Court through the present petition for review on certiorari.
ISSUE :WON the RTC is correct
HELD : The Supreme Court granted the petition. It held that a petition for annulment of judgment is an extraordinary remedy available when ordinary remedies are no longer available through no fault of the petitioner, and may be based on extrinsic fraud, lack of jurisdiction, or denial of due process. The Court found that petitioners were deliberately deprived of notice of the probate proceedings. Although Federico knew petitioners were his legitimate heirs and was aware of their addresses, he intentionally omitted their addresses in the probate petition, causing the RTC to rely on him for service of notices. The records showed that the required notices of hearing were either improperly addressed to Federico's own address, returned undelivered, or not served at all, and no affidavit of service was presented to prove valid service by registered mail. Consequently, petitioners were effectively kept ignorant of the proceedings and were deprived of the opportunity to oppose the probate of the Second Will, constituting extrinsic fraud. The Court further ruled that petitioners' action was timely, having been filed within four years from discovering the fraud, and was not barred by laches because the delay was attributable to their lack of knowledge of the proceedings. It likewise held that petitioners were denied due process since the mandatory requirement of personal notice to known heirs in probate proceedings was not complied with, and publication alone did not cure this defect. Accordingly, the Court annulled the RTC decisions admitting the Second Will to probate and approving the partition, without prejudice to the refiling of the probate proceedings in the proper court.
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