Facts:

The case involves Juan B. Bañez, Jr. (Petitioner) against Hon. Crisanto C. Concepcion, the Presiding Judge of the Regional Trial Court (RTC) in Malolos City, Bulacan, and the Estate of the late Rodrigo Gomez, represented by its administratrix, Tsui Yuk Ying (Respondents). The controversy began nearly four decades prior when Leodegario B. Ramos discovered that a parcel of land he believed he owned had been previously transferred by his mother to Ricardo Asuncion, who later sold it to Rodrigo Gomez. On February 1, 1990, Ramos filed a case against Gomez in the RTC of Valenzuela, seeking rescission of their sale contract and damages, which was docketed as Civil Case No. 3287-V-90. Before the case could be decided, Ramos and Gomez entered into a compromise agreement on October 9, 1990, which was approved by the RTC. The agreement stipulated that Ramos would execute a deed of absolute sale for a 1,233 square meter portion of land in favor of Gomez and that Bañez, as Ramos's cou...

Facts:

Background of the Case

The case involves a dispute over a parcel of land in Meycauayan, Bulacan, with an area of 1,233 square meters. The land was originally part of a larger tract owned by Leodegario B. Ramos (Ramos). Ramos discovered that his mother had transferred the land to Ricardo Asuncion, who later sold it to Rodrigo Gomez.

Initial Legal Action

On February 1, 1990, Ramos filed a case against Gomez in the Regional Trial Court (RTC) of Valenzuela (Civil Case No. 3287-V-90) seeking rescission of the sale and damages. However, on October 9, 1990, Ramos and Gomez entered into a compromise agreement, which was approved by the court. The agreement stipulated that:

1. Gomez would survey the land and segregate the 1,233 square meters.
2. Ramos would execute a deed of absolute sale in favor of Gomez for the 1,233 square meters.
3. Ramos would repay Gomez P110,000.00, guaranteed by post-dated checks issued by Ramos’s counsel, Juan B. Banez, Jr. (petitioner).

Subsequent Events

• Gomez died on November 7, 1990, and his estate, represented by Tsui Yuk Ying, sued Ramos and Banez for specific performance to recover the unpaid balance of P30,000.00 (Civil Case No. C-15750). This case was settled through another compromise agreement in 1994.
• The Estate of Gomez complied with its obligations under the 1990 compromise agreement by surveying the land, but Ramos failed to execute the deed of sale or deliver the owner’s duplicate copy of the title. Instead, Ramos and Banez registered the 1,233 square meters in Ramos’s name.

Further Legal Proceedings

• On July 6, 1995, the Estate of Gomez filed another case for specific performance (Civil Case No. 4679-V-95) to recover the land. The RTC dismissed the case on April 1, 1996, citing improper venue. The Court of Appeals (CA) affirmed the dismissal on July 24, 2001.
• On September 20, 2002, the Estate of Gomez filed Civil Case No. 722-M-2002 in the RTC of Malolos, Bulacan, to revive the 1990 compromise judgment and compel Ramos to execute the deed of sale. Banez moved to dismiss the case, arguing that the action was barred by prescription and res judicata.

RTC’s Rulings

• On February 18, 2003, the RTC granted Banez’s motion to dismiss, finding the action barred by prescription.
• On March 24, 2003, the RTC reversed itself, reinstating the case and ruling that the filing of the 1995 case interrupted the prescriptive period.
• The RTC denied Banez’s motions for reconsideration on April 21, 2003, and August 19, 2003.

Issue:

1. Whether the RTC acted with grave abuse of discretion in reversing its order of dismissal and reinstating Civil Case No. 722-M-2002.
2. Whether the action to revive the 1990 compromise judgment is barred by prescription.
3. Whether the case should be dismissed on other grounds, such as res judicata or full payment of obligations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court dismissed the petition, upheld the RTC’s reinstatement of the case, and directed Banez to pay the costs of suit. The case was remanded to the RTC for further proceedings.