G.R. No. 208928 - Ang vs. Pacunio

Andy Ang, Petitioner, acquired a parcel of land by a Deed of Absolute Sale dated July 12, 1993 and was issued Transfer Certificate of Title No. T-79051 covering a 98,851-square meter parcel originally registered in Felicisima Udiaan's name as Original Certificate of Title No. T-3593.
Severino Pacunio, Teresita P. Torralba, Susana Loberanes, Christopher N. Pacunio, and Pedrito P. Azarcon, Respondents, together with Pedrito N. Pacunio and Editha P. Yaba, filed a Complaint dated March 19, 2003 for Declaration of Nullity of Sale, Reconveyance, and Damages alleging that the July 12, 1993 sale was effected by an impostor because Udiaan died on December 15, 1972.
Respondents claimed to be grandchildren and successors-in-interest of Udiaan and asserted title to the subject land as her heirs.
Petitioner entered the subject land in 1997 and used it for a livestock business.
Respondents demanded return of the land and filed the complaint after petitioner refused to yield possession.

Respondents alleged that the sale to petitioner was void because the vendor was not Udiaan and could not have sold the land after her death.
In his Answer, petitioner denied respondents' allegations and asserted that he bought from a person representing herself as Udiaan who presented a community tax certificate and OCT No. T-3593, that he was initially prevented from entering the land by the Heirs of Alfredo Gaccion, that he later bought a portion from the Heirs of Gaccion, and that he was a buyer in good faith for value without knowledge of title defects.
Petitioner alleged that respondents were never in possession and never paid real property taxes on the subject land.

After pre-trial, the parties submitted the case for summary judgment on documents and pleadings and filed memoranda as ordered.
The Regional Trial Court (RTC), Branch 38, Cagayan de Oro City, issued a Summary Judgment dated September 12, 2006 dismissing the complaint for lack of merit.
The RTC found that respondents failed to prove successional rights to Udiaan's estate and therefore were not real parties in interest, warranting dismissal.

Respondents appealed to the Court of Appeals (CA) in CA-G.R. CV No. 00992-MIN.
In a Decision dated September 28, 2012, the CA affirmed with modification the RTC ruling by: nullifying the July 12, 1993 Deed of Absolute Sale (the Questioned Deed); declaring valid a sale between petitioner and the Heirs of Gaccion covering a 3,502-sq. m. portion; and apportioning the subject land among petitioner, the Heirs of Gaccion, and Udiaan's children.
The CA nonetheless agreed with the RTC that respondents were not real parties in interest because they were grandchildren who did not establish the availability of the *right of representation* under the Civil Code.
Petitioner moved for reconsideration, which the CA denied in a Resolution dated August 13, 2013.

Petitioner filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA Decision dated September 28, 2012 and Resolution dated August 13, 2013.
The Supreme Court promulgated its Decision on July 8, 2015.

Whether the Court of Appeals correctly declared the nullity of the Questioned Deed of Absolute Sale and apportioned the subject land to various parties despite its finding that Respondents were not the real parties in interest to the case.
Whether the CA erred in awarding reliefs and adjudicating title claims affecting non-parties such as the Heirs of Gaccion and Udiaan's children.