Case Digest (G.R. No. 78728)
Facts:
This case revolves around a Petition for Review on Certiorari filed by Artemio Baltazar and Aurora Galvez against Good Earth Enterprises, Inc. (Good Earth) seeking to annul the decision of the Court of Appeals rendered on January 14, 1987, in C.A. G.R. CV No. 00104. The parcels of land in dispute were located in Barrio San Isidro, Parañaque, comprising one parcel of 873 square meters and another parcel of 24,448 square meters. Originally, these lands were adjudicated on February 5, 1959, to Lorenzo Molera under Decree No. M-70457 in Land Registration Case No. N-1957. They were titled in his name on April 8, 1959, as Original Certificate of Title No. 1866. Good Earth acquired these lands on August 15, 1965, from the successors of Molera, and on May 19, 1967, Transfer Certificate of Title No. 191048 was issued in Good Earth’s name.
Subsequently, on March 22, 1977, Baltazar filed Civil Case No. 5552-P against Good Earth, claiming ownership and seeking reconveyance of the land. Bal
Case Digest (G.R. No. 78728)
Facts:
Ownership and Title of the Land
- The parcels of land in question, located in Barrio San Isidro, Paranaque, were originally adjudicated to Lorenzo Molera on 5 February 1959, under Decree No. M-70457 in Land Registration Case No. N-1957.
- On 8 April 1959, Original Certificate of Title (OCT) No. 1866 was issued in Lorenzo Molera's name.
- On 15 August 1965, Good Earth Enterprises, Inc. ("Good Earth") acquired the land from Molera's successors-in-interest, and Transfer Certificate of Title (TCT) No. 191048 was issued in Good Earth's name on 19 May 1967.
Civil Case No. 5552-P
- On 22 March 1977, Artemio Baltazar filed Civil Case No. 5552-P against Good Earth, claiming ownership of the land based on an alleged Spanish land grant and a deed of sale executed by Pedro Asedillo on 6 March 1976.
- Summons were attempted to be served on Good Earth at its address, 666 Muelle de Binondo, Manila, but Deputy Sheriff Pre certified that Good Earth could not be found there.
- On 1 April 1977, Baltazar filed a motion for leave to serve summons by publication, which was granted. The summons were published in the "Times Journal" on 6, 13, and 20 August 1977.
- Good Earth failed to file an answer, and the trial court declared it in default. On 3 November 1977, the court issued a default judgment in favor of Baltazar, ordering Good Earth to reconvey the land to Baltazar and canceling TCT No. 191048.
- On 28 February 1978, TCT No. 191048 was canceled, and TCT No. 63805 was issued in Baltazar's name. Baltazar subsequently sold portions of the land to Aurora Galvez, Rizaliana Garments, Inc., and BGB Development Corporation.
Good Earth's Complaint
- On 9 August 1979, Good Earth filed Civil Case No. PQ-7410-P to annul the default judgment in Civil Case No. 5552-P, arguing that the trial court lacked jurisdiction over its person due to improper service of summons.
- The trial court dismissed Good Earth's complaint, holding that service of summons by publication was proper and that Baltazar's vendees were purchasers in good faith.
- On appeal, the Court of Appeals reversed the trial court's decision, reinstating TCT No. 191048 in Good Earth's name and ordering the cancellation of the titles issued to Baltazar and his vendees.
Issue:
Propriety of Service of Summons by Publication
- Whether the service of summons by publication upon Good Earth in Civil Case No. 5552-P was valid, given that Good Earth is a domestic corporation and the action was in personam.
Rights of Baltazar's Vendees
- Whether Baltazar's vendees, who claimed to be purchasers in good faith, acquired any rights to the land despite Baltazar's lack of valid ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied the Petition for Review and affirmed the Court of Appeals' decision, reinstating Good Earth's title to the land and canceling the titles issued to Baltazar and his vendees. The Court held that the trial court's judgment in Civil Case No. 5552-P was null and void due to lack of jurisdiction over Good Earth, and Baltazar's vendees acquired no rights to the land.