G.R. No. L-8080 - Belleza vs. Zandaga

Mariano Belleza, the plaintiff-appellant, purchased a piece of land at an execution sale.
The plaintiff received a definitive deed of sale on July 25, 1947, which purportedly perfected his legal title to the property.
The sale and issuance of the definitive deed established, as a matter of law, that the purchaser becomes the absolute owner of the property described therein.

On July 81, deputy sheriff Emilio Cle Guzman put Belleza in possession of a parcel identified by barrio lieutenant Aniceto Zandaga as being the one described in the deed.
It subsequently emerged that the lot in which Belleza was put in possession differed from the one detailed in the definitive deed.
Upon realizing the discrepancy and that the actual property described in the deed was being occupied by Zandaga, Belleza demanded possession.

Belleza alleged that Zandaga, by concealing the true identity of the property, maliciously deprived him of possession and the fruits of the land.
The complaint demanded that Zandaga be compelled to show his title; if proven inferior, Belleza should be declared the rightful owner and entitled to the possession of the land and its fruits.
Additional relief included an award for damages, attorney’s fees, costs, and a declaration rendering the provincial sheriff subsidiarily liable if Zandaga could not satisfy the judgment.

The original complaint was filed in the Court of First Instance of La Union.
Instead of answering the complaint, both defendants moved for dismissal on the ground that the complaint did not state a cause of action.
The trial court granted the motion to dismiss, holding that, among other reasons, the plaintiff’s remedy was exclusively under section 32 of Rule 39.
Belleza, disagreeing with this dismissal, directly appealed to the Supreme Court, given that the issue raised was purely legal.

Whether the receipt of the definitive deed perfected Belleza’s legal title to the property purchased at an execution sale.
Whether Belleza, as the absolute owner by virtue of the definitive deed, was entitled to possession and the full benefits (rents and fruits) of the property.

Whether the claim of Aniceto Zandaga as the “successor in interest” of the judgment debtor could override the rights of the purchaser with a perfected title.
Whether the allegations in the complaint were sufficient to establish that Zandaga had a better right to the property than Belleza.

Whether dismissing the complaint on the basis that it did not state a cause of action was proper, considering the hypothetical admissions of the facts.
Whether the complaint should have been dismissed solely under the premise that the available remedy was only under Rule 39, Section 32, or if it also gave rise to an independent right to recover possession.

Whether the complaint sufficiently alleged facts that would render the provincial sheriff subsidiarily liable in the event that Zandaga’s title proved inferior.
Whether the provincial sheriff was appropriately included as a co-defendant for the alleged acts relating to the concealment of the property's identity.