JUSTICE MARTIN VILLARAMA, JR.: DIRECT AND COLLTERAL ATACK ON THE TITLE

An action is deemed an attack on a title when its objective is to nullify the title, thereby challenging the judgment pursuant to which the title was decreed.  The attack is direct when the objective is to annul or set aside such judgment, or enjoin its enforcement.  On the other hand, the attack is indirect or collateral when, in an action to obtain a different relief, an attack on the judgment is nevertheless made as an incident thereof (Sarmiento v. Court of Appeals, G.R. No. 152627, September 16, 2005, 470 SCRA 99, 107-108 cited in Roman Catholic Archbishop of San Fernando Pampanga vs. Fernando Soriano Jr., et al., G.R. No. 153829, August 17, 2011,VILLARAMA, JR., J.).