Title
Baleares vs. Espanto
Case
G.R. No. 247844
Decision Date
Jul 26, 2023
A disputed land title case involving voided mortgage, foreclosure, and bad faith transactions, remanded for trial due to procedural dismissal, ensuring due process and justice.
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Case Digest (G.R. No. 247844)

Facts:

  1. Background of the Property: The case involves a parcel of land covered by Transfer Certificate of Title (TCT) No. RT-57 (9482), registered in the name of Santos Baleares, his siblings, and his nephew as co-owners.
  2. Mortgage and Foreclosure: In 1988, the Baleares siblings mortgaged the property to Arnold V. Maranan. Arnold failed to enforce his mortgage rights within the 10-year prescriptive period, leading petitioners to file a complaint in 1998 to cancel the mortgage annotation on the title.
  3. RTC and CA Decisions: The Regional Trial Court (RTC) ruled in favor of petitioners, declaring the mortgage and foreclosure void due to prescription and non-compliance with legal requirements. This decision was affirmed by the Court of Appeals (CA) and became final in 2008.
  4. Subsequent Transactions: Despite the final judgment, Arnold consolidated the title and sold the property to Felipe Espanto, who initiated ejectment proceedings against petitioners.
  5. First Case for Nullification: Petitioners filed a case to nullify the foreclosure and subsequent transactions, but the case was dismissed for failure to attend pre-trial hearings.
  6. Present Case: Petitioners filed another case for annulment of title and related documents, which was dismissed by the RTC on the ground of res judicata, as the issues were identical to the previously dismissed case.

Issue:

  1. Whether the Court of Appeals erred in dismissing the appeal for lack of jurisdiction.
  2. Whether the filing of the Present Case is barred by the prior dismissal of the First Case based on res judicata.
  3. Whether the petition should be given due course in the interest of substantial justice.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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