Short answer. It depends on the ground. A petition for annulment of judgment based on extrinsic fraud must be filed within four years from discovery of the fraud. One based on lack of jurisdiction has no fixed period — it may be brought at any time before the claim is barred by laches or estoppel.
What the law says
If based on extrinsic fraud, the action must be filed within four years from its discovery; and if based on lack of jurisdiction, before it is barred by laches or estoppel.
Rule 47, Section 3 — Period for filing action. Read the full provision →
Two grounds, two different clocks
Rule 47 recognises two grounds for annulling a final judgment, and each carries its own time limit. Section 3 provides: If based on extrinsic fraud, the action must be filed within four years from its discovery; and if based on lack of jurisdiction, before it is barred by laches or estoppel. The first limit is a fixed period that begins on a fact — discovery. The second is not a counted period at all but a flexible bar, measured by your own conduct after learning of the judgment. Identifying your true ground is therefore the first step in knowing how much time you actually have.
Four years from discovery of the fraud
The four-year period for extrinsic fraud runs from its discovery, not from the date the judgment was rendered or became final. Extrinsic fraud, in general terms, is fraud that kept you out of the case itself — you were prevented from presenting your side at all, rather than merely losing on evidence contested inside the trial. Because the clock starts at discovery, the date you actually learned of the fraudulent judgment becomes a fact you must be able to prove. A petitioner who cannot show when discovery happened invites the argument that the four years lapsed long ago.
Lack of jurisdiction: no fixed period, but not forever
Where the ground is lack of jurisdiction, the petition is limited not by a counted period but by the requirement that it come before it is barred by laches or estoppel. Laches is unreasonable delay in asserting a right after you could have acted; estoppel arises from conduct that led others to rely on the judgment. In practical terms, a judgment rendered without jurisdiction can be attacked even years later — but sleeping on the remedy after learning of the judgment, or behaving in ways that accept it, can close the door. Time still matters, even without a deadline.
A last-resort remedy, so mind the prerequisites
Annulment of judgment is an extraordinary remedy, available only where the ordinary remedies of new trial, appeal, or petition for relief can no longer be taken through no fault of the petitioner. That means the timeline of the whole case matters, not just the four-year count: a party who let those earlier remedies lapse through neglect may be barred regardless of the calendar. Before anything else, fix the key dates in writing — when judgment was rendered, when it became final, and when you first learned of the fraud or the jurisdictional defect — because the petition will stand or fall on them.