Case Digest (G.R. No. 133495) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1973, petitioner Douglas F. Anama entered into a contract to buy a property owned by Philippine Savings Bank (PSB) on an installment basis. Anama defaulted on payments, leading PSB to rescind the contract and retain title to the property. PSB subsequently sold the property to respondents Spouses Saturnina Baria and Tomas Co (Spouses Co), who completed payment and registered the title under TCT No. 14239. Anama filed a case for nullity of sale, cancellation of title, and specific performance against PSB, the Spouses Co, and the Register of Deeds. The Regional Trial Court (RTC), Pasig City Branch 167, dismissed Anama’s complaint on August 21, 1991, upholding the sale’s validity. Anama appealed unsuccessfully to the Court of Appeals (CA) and the Supreme Court (SC), with the SC affirming the dismissal on January 29, 2004; the decision became final and executory on July 12, 2004. The Spouses Co moved for issuance of writ of execution, granted by the RTC on November 25, 2005. Anama Case Digest (G.R. No. 133495) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Douglas F. Anama (Petitioner) entered into a Contract to Buy on an installment basis with Philippine Savings Bank (PSB) in 1973 for a real property covered by Transfer Certificate of Title (TCT) No. 301276, owned by PSB.
- Anama defaulted on payments; PSB rescinded the contract and retained title.
- PSB sold the property to Spouses Saturnina Baria and Tomas Co (Co Spouses), who fully paid and registered the property under TCT No. 14239.
- Anama filed a complaint for nullity of the deed of sale, cancellation of TCT, and specific performance with damages against PSB, the Co Spouses, and the Register of Deeds.
- Procedural History
- August 21, 1991: Regional Trial Court (RTC), Branch 167, Pasig City dismissed Anama's complaint and upheld the sale's validity.
- Anama appealed to the Court of Appeals (CA) and this Court but was unsuccessful.
- January 29, 2004: Supreme Court rendered judgment denying Anama's petition sustaining the sale's validity; became final and executory on July 12, 2004.
- The Co Spouses moved for execution of the judgment; RTC granted on November 25, 2005.
- Anama moved for reconsideration, arguing the Co Spouses’ motion for execution was fatally defective due to lack of affidavit of service and defective notice of hearing.
- RTC denied reconsideration motions; Anama appealed to the CA.
- Issues Raised by Petitioner
- The RTC and CA erred in taking judicial cognizance of a defective motion for execution that lacked mandatory notice of hearing addressed to parties.
- Motion lacked the required affidavit of service.
- Alleged fraud by Spouses Co and PSB involving manipulation of the Transcript of Stenographic Notes (TSN) and misrepresentation.
- Respondents’ Positions
- Co Spouses argued petition raised mixed questions of fact and law.
- Claimed substantial compliance with notice and hearing requirements; motion served on Anama’s counsel.
- PSB emphasized that judgment was final and executory with right to execution.
- PSB cited technicality arguments by petitioner to delay justice and that notice to counsel sufficed.
Issues:
- Whether the motion for execution filed by Spouses Co was defective for lack of proper notice of hearing addressed to the parties.
- Whether the motion for execution was invalid due to absence of the mandatory affidavit of service.
- Whether the alleged fraud perpetuated through "dagdag-bawas" (intercalation) in the TSN and falsification of documents warrants the suspension or invalidation of the writ of execution.
- Whether requiring strict compliance with notice and service rules applies when a judgment is final and executory.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)