Facts:

The case involves a petition for review on certiorari filed by Maria G. Baluyut, Beatriz G. David, Consolacion G. Zamora, Purita G. Tongol, Luz G. Viray, Jose S. Guiao, and Jesus Guiao (collectively referred to as "petitioners") against Rodolfo Guiao, Trinidad G. Mandal, and Spouses Nicolas Tubil and Iluminada Canlas (collectively known as "respondents"). The case originated from the Regional Trial Court (RTC) of Guagua, Pampanga. On July 7, 1988, the petitioners filed a complaint seeking to nullify a donation made by Rosario S. Vda. De Guiao (a petitioner) to the respondents concerning a 245.42 square meter property covered by Original Certificate of Title No. 4528. The petitioners contended that the donation was invalid and sought the reconveyance of the property.

After a trial on the merits, the RTC decided in favor of the petitioners, declaring the donation void and ordering the respondents to return the property and associated amounts. The decision was s

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Facts:

Background of the Case

• On July 7, 1988, petitioners filed a complaint before the Regional Trial Court (RTC) of Guagua, Pampanga, seeking to declare null and void:
• A donation of a 245.42-square meter portion of a property (covered by Original Certificate of Title No. 4528) purportedly executed inter vivos by plaintiff Rosario S. Vda. De Guiao in favor of respondents Rodolfo Guiao and Trinidad G. Mandal.
• A subsequent sale of the same property portion by the said respondents in favor of their co-defendants, spouses Nicolas Tubil and Iluminada Canlas.
• The RTC trial on the merits resulted in a decision in favor of the petitioners which declared the donation null and void, and ordered:
• The reconveyance of the 245.42-square meter lot from defendant spouses Tubil and Canlas back to petitioner Rosario S. Vda. De Guiao.
• The return of sums amounting to P125,000.00 and P16,500.00 by defendants Rodolfo Guiao and Trinidad Mandal, respectively, representing the purchase prices for their respective halves of the sold property.
• The payment of attorney’s fees and costs of suit by all defendants.
• On appeal, the Court of Appeals reversed the RTC decision, dismissing the complaint and rendering costs against the appellees.
• After the judgment became final and executory on September 23, 1992, respondent spouses Tubil and Canlas, on April 27, 1995, filed a motion to take possession of their property by requesting a writ of possession.
• The RTC granted the motion on May 23, 1995, and the writ was issued on May 26, 1995.
• Petitioners, not satisfied with the issuance of the writ of possession, subsequently:
• Filed a Motion to Quash the Writ of Possession on June 9, 1995, arguing that the dismissal of the complaint did not grant respondents the right to take possession of the property.
• Had the Motion to Quash denied on May 24, 1996.
• Filed a Motion for Reconsideration, which was again denied on August 28, 1996.
• Filed a Notice of Appeal on September 12, 1996, from the May 24, 1996 Order, which was denied on November 18, 1996, and again upon a subsequent Motion for Reconsideration on March 7, 1997.

Petition for Certiorari Before the Court of Appeals

• Petitioners raised two main issues in their petition for certiorari:
• That the public respondent acted in excess of its jurisdiction in issuing the writ of possession, given the apparent divergence between the writ and the underlying decisions.
• That the public respondent acted in excess of its jurisdiction by denying the petitioners’ notice of appeal, despite such appeal being allowed under law as an exception to the general rule.
• The Court of Appeals, while recognizing an error in denying the notice of appeal under the exception provided in Paulino vs. Court of Appeals, ultimately dismissed the petition for certiorari.

Rationale Adopted by the Appellate Court

• The appellate court affirmed that:
• The valid donation executed in favor of respondents transferred ownership of the disputed property.
• The subsequent valid sale transferred the property to respondent spouses Tubil and Canlas.
• An order granting possession (i.e., the writ of possession) is inherent to the adjudication of ownership, which includes both title and possession.
• The courts relied on past Supreme Court rulings citing that:
• A judgment is not limited solely to what appears on its face but also includes what is necessarily implied, such as the delivery of possession (Perez vs. Evite, Olego vs. Rebueno, among others).

Petition for Review on Certiorari Before the Supreme Court

• On December 23, 1998, petitioners filed a petition for review assailing the appellate decision.
• They reiterated that the appellate court erred in dismissing the petition, particularly regarding:
• The denial of the notice of appeal.
• The court’s ruling on the validity of the writ of possession—a matter they contended should have been resolved on appeal, not in the petition for certiorari.
• Petitioners argued that the appellate court should have:
• Ordered the RTC to forward the case records for proper appellate review, especially after acknowledging the error in denying the notice of appeal.

Final Disposition

• The Supreme Court, after reviewing the petition and the record, found:
• The writ of possession did not vary the terms of the original judgment as it merely enforced the judgment’s inherent adjudication of ownership.
• The petitioners had no independent right to possession aside from their disputed claim of ownership.
• The appellate court’s ruling on the writ of possession was correct, and petitioners were estopped from challenging an issue they themselves had raised before.
• Accordingly, the petition for review was denied for lack of merit.

Issue:

Whether the issuance of the writ of possession by the RTC, granting possession to respondent spouses Tubil and Canlas, constitutes an excess of jurisdiction or grave abuse of discretion, considering the underlying decisions on the donation and sale of the property.

• Did the writ of possession vary the terms of the certain judgment, and if so, was such variance appealable?

Whether the denial of the petitioners’ notice of appeal, which the petitioners argued was erroneously denied under an exception to the rule that only final judgments are appealable, was proper.

• Is the notice of appeal, as filed by petitioners, valid under the exception provided in the case of Paulino vs. Court of Appeals and related jurisprudence?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)