Case Digest (G.R. No. 189626)
Facts:
Amoguis v. Ballado, G.R. No. 189626, August 20, 2018, Supreme Court Third Division, Leonen, J., writing for the Court. Petitioners are Gregorio Amoguis and Tito Amoguis (the Amoguis Brothers); respondents are Concepcion Ballado and Mary Grace Ballado Ledesma (the Ballado Spouses) and St. Joseph Realty, Ltd.On November 24, 1969 the Ballado Spouses entered into two instalment contracts (Contracts Nos. 5(M) and 6(M)) with St. Joseph Realty to buy two subdivision lots in Dadiangas Heights, General Santos City. They paid small down payments and made monthly amortizations until 1979 when St. Joseph Realty’s collector, Crisanto Pinili, allegedly refused further collections because the Ballados had erected a small caretaker house. The Ballados received no regular collection effort thereafter. On February 17, 1987 the Ballados discovered that St. Joseph Realty had purportedly rescinded the contracts and, on February 9, 1987, St. Joseph had already sold the lots to Epifanio Amoguis (father of the petitioners); titles issued to the Amoguis Brothers on August 18, 1987.
The Ballado Spouses filed a Complaint on December 23, 1987 for damages, injunctive relief, cancellation/annulment of titles and specific performance, seeking among others cancellation of the titles issued to the Amoguis Brothers and reconveyance to them. St. Joseph Realty answered and pleaded, among other defenses, that the Regional Trial Court (RTC) lacked jurisdiction because the Housing and Land Use Regulatory Board (HLURB, successor to the National Housing Authority) had exclusive jurisdiction over subdivision disputes. The Amoguis Brothers filed an answer with cross- and counterclaims. Trial followed intermittently; the case was archived in 1989 and revived in 1994. The Ballados presented witnesses and various documents in 1996.
The RTC (Branch 22, General Santos City) rendered judgment in favor of the Ballados, ordering reconveyance, damages against St. Joseph, cancellation of the Amoguises’ titles, and removal of the Amoguises’ improvements. The Amoguis Brothers timely appealed to the Court of Appeals; St. Joseph Realty failed to file its appeal brief and was considered to have abandoned its appeal. On September 26, 2008 the Court of Appeals (CA-G.R. CV No. 73758-MIN) affirmed the RTC with modifications: it nullified the Amoguises’ titles, affirmed awards of moral/exemplary damages and attorney’s fees (to be paid solely by St. Joseph), ordered execution of a deed of sale upon full payment by the Ballados, and ordered refund by St. Joseph to the Amoguises with interest; the CA discussed, on its own, that jurisdiction over such subdivision disputes was vested in the then National Housing Authority/HLURB under Presidential Decrees Nos. 957 and 1344 but concluded that St. Joseph Realty and the Amoguis Brothers had failed to timely raise the jurisdictional objection and were estopped by laches.
The Amoguis Brothers filed a motion for reconsideration which the Court of Appeals denied on August 7, 2009. They then filed a Petition for Review on Certiorari un...(Pro-only)
Issues:
- Was the RTC’s alleged lack of subject-matter jurisdiction waived or lost by estoppel/laches so that petitioners may not raise it now?
- May testimonial and documentary evidence that were not formally offered nonetheless be considered where the opposing party failed to timely object?
- Are petitioners Gregorio and Tito Amoguis buyers in good faith entitl...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)