Title
Bon-Mar Realty and Sport Corp. vs. Spouses De Guzman
Case
G.R. No. 182136-37
Decision Date
Aug 29, 2008
Spouses De Guzman sought property reconveyance after disputed sales; BON-MAR intervened, claiming ownership; SC ruled BON-MAR’s intervention valid, delaying De Guzmans’ writ of possession.
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Case Digest (G.R. No. 182136-37)

Facts:

Ownership and Initial Transactions

The Spouses Nicanor and Esther De Guzman (De Guzmans) owned two lots in Greenhills, San Juan, Metro Manila, covered by Transfer Certificates of Title (TCT) Nos. 9052 and 9053. In 1987, the De Guzmans borrowed money from Mario and Erlina Siochi (Siochis) for Nicanor’s political campaign, using the properties as collateral. A deed of sale was executed in favor of the Siochis, and TCT Nos. 9052 and 9053 were canceled, replaced by TCT Nos. 275-R and 276-R in the Siochis’ name.

Subsequent Transfers

The Siochis sold the lots to Jayme and Evelyn Uy (Uys), who were issued TCT Nos. 277-R and 278-R. The Uys then leased the properties to Roberto Salapantan.

Legal Proceedings Initiated by De Guzmans

Upon discovering the transfers, the De Guzmans filed Civil Case No. 56393 to annul the sales to the Siochis and Uys, as well as the lease to Salapantan. On December 28, 1990, the Regional Trial Court (RTC) ruled that the agreement between the De Guzmans and Siochis was an equitable mortgage, nullifying the sales and lease, and ordering reconveyance of the properties to the De Guzmans. The Siochis and Uys appealed, but the Court of Appeals affirmed the RTC’s decision.

BON-MAR’s Claim

While the Uys’ appeal was pending, BON-MAR Realty and Sport Corporation filed Civil Case No. 67315 against the Uys and the Register of Deeds, claiming it had purchased the lots from the De Guzmans’ successors. BON-MAR alleged that the Uys had forged documents to transfer the properties back to their name.

Multiple Legal Battles

  • In Civil Case No. 67315, the RTC ruled in favor of BON-MAR, canceling the Uys’ titles and reinstating BON-MAR’s ownership. This decision became final on September 5, 2004.
  • In Civil Case No. 56393, the De Guzmans moved for a writ of execution, which BON-MAR opposed, claiming it had already acquired the properties. The RTC denied BON-MAR’s motion to intervene.
  • BON-MAR also filed SCA No. 2988-SJ for indirect contempt against the Register of Deeds for refusing to cancel the Uys’ titles and issue new ones in BON-MAR’s name.

Appellate Court Decisions

The Court of Appeals consolidated the cases and denied BON-MAR’s petition to intervene in Civil Case No. 56393, affirming the issuance of a writ of possession to the De Guzmans. However, it granted the De Guzmans’ leave to intervene in SCA No. 2988-SJ.

Issue:

  1. May BON-MAR intervene in Civil Case No. 56393?
  2. Are the De Guzmans entitled to a writ of possession?
  3. May the De Guzmans intervene in SCA No. 2988-SJ?

Ruling:

  1. Yes, BON-MAR may intervene in Civil Case No. 56393. BON-MAR has a legal interest as it claims ownership over the properties. Its intervention is necessary to prevent unjust enrichment or double recovery by the De Guzmans.
  2. No, the De Guzmans are not entitled to a writ of possession. The writ must be held in abeyance pending the resolution of BON-MAR’s claim.
  3. No, the De Guzmans cannot intervene in SCA No. 2988-SJ. Contempt is not the proper remedy; the correct procedure is a consulta with the Commissioner of the Land Registration Authority.

Ratio:

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