Case Digest (G.R. No. 156882)
Facts:
Associated Labor Unions (ALU) and Divine Word University Employees Union-ALU (DWUEU-ALU) v. Court of Appeals, The Roman Catholic Archbishop of Palo, Leyte, and Divine Word University of Tacloban, G.R. No. 156882, October 31, 2008, Supreme Court Second Division, Velasco Jr., J., writing for the Court.The dispute traces to a Deed of Sale executed on October 1, 1958 by which The Roman Catholic Archbishop of Palo, Leyte (RCAP) sold thirteen parcels of land to Societas Verbum Dei (SVD) with express conditions restricting use for educational purposes and providing a reversionary right to the RCAP in specified circumstances. Although the deed was not notarized, new Transfer Certificates of Title (TCTs) were later issued in the name of the SVD without annotation of the deed’s conditions and the RCAP’s reversionary interest. The school already existing on some of the lots became St. Paul’s College, later renamed Divine Word College and then Divine Word University of Tacloban (DWUT).
A protracted labor case between DWUT (run by SVD) and the Union culminated in this Court’s decision in Divine Word University of Tacloban v. Secretary of Labor and Employment, G.R. No. 91915 (promulgated September 11, 1992), which left DWUT owing substantial monetary obligations (about PhP 200 million by early 1994). On April 27, 1995 RCAP filed Cadastral Case No. 95-04-08 in the RTC, Branch 8, Tacloban, seeking registration of the 1958 deed and annotation of the RCAP’s conditions, restrictions, and reversionary interest on the corresponding SVD titles. DWUT announced its closure effective June 15, 1995; the NCMB ordered partial satisfaction of the DWUT judgment on July 7, 1995. The Union then filed an amended complaint for Unfair Labor Practice, Illegal Dismissal and Damages before the Regional Arbitration Branch (NLRC Case No. RCB-VIII-7-0299-95), alleging among other things that RCAP remained solidarily liable because of the deed’s conditions.
On August 3, 1995 the Union moved to intervene in the cadastral case asserting a judgment lien under the final February 11, 1994 decision (G.R. No. 91915) and invoking Article 110 of the Labor Code and Arts. 2242–2244 of the Civil Code. The RTC, by Order dated March 8, 1996, dismissed the petition for annotation, holding it lacked jurisdiction and finding RCAP guilty of forum shopping, and treated the Union’s intervention motion as moot; the RTC denied reconsideration on June 7, 1996 chiefly on the ground of laches. RCAP appealed to the Court of Appeals as CA-G.R. CV No. 56482.
While the appeal was pending, RCAP, DWUT and the Union entered into a February 24, 1997 Memorandum of Agreement (MOA) settling certain monetary claims (PhP 100 million, with dacion en pago of particular properties for part of the amount) and providing for reopening of DWUT. The Court of Appeals, in a decision promulgated April 29, 2002 (authored by Justice Andres B. Reyes, Jr.), reversed the RTC’s March 8 and June 7, 1996 Orders and granted RCAP’s petition for annotation, holding the RTC erred in applying laches and concluding the Union had no legal personality because it failed to appeal the RTC orders. The CA denied the Union’s motion for reconsideration by its January 20, 2003 resolution.
The Union and ALU filed a petition for review on certiorari under Rule 45 contesting (1) the CA’s allowance of annotation of encumbrance and reversionary interest on th...(Subscriber-Only)
Issues:
- Did the Union acquire legal personality to intervene in Cadastral Case No. 95-04-08?
- Did laches bar RCAP’s petition for annotation and, accordingly, did the Court of Appeals err in ordering the annotation of encumbrances and reversionary interest o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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