Case Digest (G.R. No. L-38773)
Facts:
The case involves a dispute between Miguel Alfonso and several other petitioners, including Gomercindo Bolante, Carlos Batungbacal, and Gregorio Pilorin, among others, as the petitioners, against Hon. Judge Bernardo P. Fernandez of the Court of First Instance of Zambales, as well as Raymundo Dela Paz and members of the Dela Paz family, who are the respondents. This matter was brought before the Supreme Court on November 15, 1974, although preliminary hearings occurred earlier, specifically on October 11, 1974. The underlying litigation took place in the Court of First Instance of Zambales, with the parties disputing whether the land occupied by the petitioners was covered under Transfer Certificate of Title (T.C.T.) No. 14807, retained by the respondents. Throughout the case, there was mention of the purported admission by Atty. Jose Sarte, who previously represented the petitioners, which raised ambiguities regarding their position in the litigation. Consequently, in an effort
Case Digest (G.R. No. L-38773)
Facts:
- Petitioners: Miguel Alfonso, Gomercindo Bolante, Carlos Batungbacal, Gregorio Pilorin, Alberto De Guzman, Jacobo Isip, Alfredo Kilakil, Rodito Morabe, Alfredo Panugao, Bayani Ramirez, Agustin Del Rosario, and Ramon De Vera, Jr.
- Respondents: Hon. Judge Bernardo P. Fernandez (acting through the Court of First Instance of Zambales, Branch III, Olongapo City) and private respondents including Raymundo Dela Paz, Placido De La Paz, Jose Dela Paz, Jr., Iloina Dela Paz, Augusto Dela Paz, Norita Dela Paz, Leonora Dela Paz, and Victoria Dela Paz.
- The dispute centers on whether the land occupied by the petitioners is included in Transfer Certificate of Title (T.C.T.) No. T-14807 held by the private respondents.
Parties and Nature of the Dispute
- During the hearing on October 11, 1974, the Court noted the ambivalence in the admission made by Atty. Jose Sarte (former counsel of the petitioners) during the pre-trial phase.
- The ambivalent admission raised questions regarding its impact and relevance; however, the parties agreed that this was not the core issue.
- The sole issue was determined to be the proper inclusion of the land within T.C.T. No. T-14807.
Procedural History and Pre-Trial Developments
- The parties submitted a written compromise agreement, inaccurately referred to as the Stipulation of Facts, which was approved by the Court.
- Key Provisions of the Compromise Agreement:
- The parties agreed to proceed with the trial in the lower court irrespective of the ambivalent pre-trial admission of Atty. Jose Sarte.
- A relocation survey was mandated on the land covered by T.C.T. No. T-14807 to definitively determine its boundaries and correct inclusion.
- Financial Arrangements for the Relocation Survey:
- The cost of the relocation survey would be shared equally by both parties—one-half borne by the defendants and the other half by the plaintiffs.
- The winning party in the eventual determination would recover the incurred survey expenses from the losing party as part of the costs.
- Consent and Binding Effect:
- All parties involved in Civil Case No. 1133-0 of the Court of First Instance of Zambales, Branch III, except for the nonrepresented defendant Antonio Coronel, agreed to abide by the outcome of the relocation survey.
- The stipulation was submitted and agreed upon during the Supreme Court hearing, reflecting a mutual resolution mechanism for the pending dispute.
Compromise Agreement (Stipulation of Facts)
- The Supreme Court approved the stipulated compromise agreement.
- The order directed all parties, including the respondent judge or his representative, to abide by and enforce the terms of the compromise.
- The decision explicitly stated that no costs would be imposed on either party as a result of this order.
Court’s Administrative Order
Issue:
- Whether the land occupied by the petitioners falls within the scope of Transfer Certificate of Title (T.C.T.) No. T-14807 held by the private respondents.
Core Contention
- The impact, if any, of the ambivalent admission made by Atty. Jose Sarte during the pre-trial on the determination of the disputed land area.
- The judicial acceptability and binding nature of a compromise agreement (mis-termed as the Stipulation of Facts) in addressing land disputes.
Subsidiary Consideration
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)