Case Digest (G.R. No. 217111)
Facts:
Lilah Gail Corpuz Alfiler v. Sps. John Cayabyab and Geraldine Cayabyab, G.R. No. 217111, March 13, 2023, Supreme Court First Division, Gesmundo, C.J., writing for the Court. Petitioner Lilah Gail Corpuz Alfiler sought relief from the Court after the Court of Appeals dismissed her certiorari petition challenging the Regional Trial Court’s affirmation of a Metropolitan Trial Court ejectment judgment favoring Spouses John and Geraldine Cayabyab, represented by attorney-in-fact Jose Vasallo.The dispute concerns a parcel at No. 186 Pajo Street, Quezon City (266.9 sq.m.) titled in Quintin Santiago, Jr. In March 1985 Quintin filed an ejectment complaint before the Lupon Tagapamayapa against petitioner’s mother and others; on May 1, 1985 the parties executed an Amicable Settlement providing for a sale at P550.00/sq.m. and installment payments. The alleged buyers (predecessors-in-interest of petitioner) made partial payments totaling P72,425.00, the last in June 1986. Quintin died on March 12, 1997.
On August 20, 1997 a Deed of Absolute Sale (DOAS) was purportedly executed in favor of Spouses Cayabyab, allegedly by Quintin through his attorney-in-fact Norman Santiago. On March 18, 2010 the Cayabyabs filed a Complaint for Ejectment in the Metropolitan Trial Court (MeTC), alleging ownership under the DOAS and demanding possession; they served demand May 8, 2009. Petitioner and co-defendants answered, asserting (inter alia) that the DOAS was void because Quintin was already dead when it was executed and because no Special Power of Attorney (SPA) was produced; they also relied on the 1985 Amicable Settlement and claimed the MeTC lacked jurisdiction because the action was filed more than one year after dispossession.
The MeTC (Presiding Judge Manuel B. Sta. Cruz, Jr.) rendered judgment for plaintiffs on January 3, 2011, ordering petitioner and others to vacate and pay monthly damages, attorney’s fees and costs. The MeTC found respondents proved ownership by preponderance. Petitioner and Meda appealed the MeTC decision to the RTC under Rule 40. The RTC (Judge Bernelito R. Fernandez) affirmed the MeTC in a January 9, 2013 Decision and denied reconsideration on October 17, 2013.
Petitioner filed a Petition for Certiorari under Rule 65 with the Court of Appeals on November 22, 2013. The CA dismissed the petition on December 13, 2013 for being the wrong mode of appeal (Rule 42 was the appropriate remedy) and denied reconsideration on February 17, 2015. Petitioner then filed a Petition for Review ...(Pro-only)
Issues:
- Did the Court of Appeals err in dismissing petitioner’s Rule 65 petition as the wrong mode of appeal when petitioner filed against the RTC’s decision instead of filing a Rule 42 petition for review, notwithstanding petitioner’s contention that substantial justice required liberal construction of the rules?
- Did the lower courts correctly adjudicate respondents’ claim to de facto possession based on the August 20, 1997 Deed of Absolute Sale, or should the DOAS be declared ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)