Case Digest (G.R. No. 51983)
Facts:
Adoracion Valera Bringas v. Harold M. Hernando and Leopoldo B. Gironella, G.R. No. 51983, February 29, 1988, Special Former Second Division, Fernan, J., writing for the Court. Petitioner Adoracion Valera Bringas sued the presiding judges of Branches I and II of the Court of First Instance of Abra and various Valera heirs (private respondents) challenging orders and execution proceedings in Abra CFI Civil Case No. 1044 and related acts to recover properties allegedly belonging to the estate of Francisco Valera.The long family litigation began when Celso and Virgilio Valera filed a petition for administration of Francisco’s intestate estate on September 29, 1945; Virgilio was appointed administrator and later collected insurance and war-damage payments. Adoracion intervened in 1952 claiming status as an acknowledged natural child; the Abra CFI later declared her such (Civil Case No. 374), and she became administratrix on April 4, 1964. In July 1964 the probate court ordered Virgilio and Celso to pay P100/month plus interest as rentals representing Francisco’s share in the ancestral residence. A writ of execution issued April 15, 1966 and a sheriff’s sale occurred April 3, 1967; Adoracion was the lone bidder and took possession.
The heirs of Virgilio petitioned this Court in G.R. No. L-27526 (Angelita Vda. de Valera et al. v. Ofilada et al., 59 SCRA 96) seeking to set aside, insofar as Virgilio’s heirs were concerned, the 1964 orders, the writ of execution and the April 3, 1967 sale; this Court held the probate court erred insofar as it adjudged liabilities of a deceased person without hearing the legal representative and set aside those proceedings “insofar as the heirs of Virgilio Valera or his estate are concerned,” while expressly reserving the right of others to pursue proper claims against Virgilio’s administrator.
Celso and other heirs pursued multiple collateral and direct actions (CA-G.R. No. 37751; L-26560; L-27886; L-29896; L-35292; Adm. Matter No. P-159) challenging various orders and executions; many of these petitions were dismissed or denied by the Court of Appeals and this Court for lack of merit or procedural defects, and this Court sustained that line of rulings in several resolutions cited in the record.
Subsequently Celso’s heirs filed Abra CFI Civil Case No. 1044 seeking restoration of properties sold at public auction. Judge Harold M. Hernando denied petitioner Adoracion’s motion to dismiss, issued a judgment on the pleadings (January 11, 1980) ordering return of possession to Celso’s and Virgilio’s heirs, and an order of execution (January 17, 1980). Petitioner filed a petition for certiorari, prohibition and mandamus with this Court (Rule 65) challenging those orders and obtained a temporary restraining order while the matter was pending.
On September 24, 1986 this Court rendered a decision affirming Judge Hernando’s judgment on the pleadings and the execution order insofar as they applied the benefits of L-27526 also to the heirs of Celso Valera. Petitioner filed a motion for reconsideration, arguing that Civil Case No. 1044 was barred by prior judgments (including G.R. No. L-27526 and multiple subsequent Supreme Court and appellate decisions) and that Judge Hernando acted with grave abuse of discretion and without jurisdiction. The Co...(Subscriber-Only)
Issues:
- Is Abra CFI Civil Case No. 1044 barred by prior judgments such that it should be dismissed (res judicata and prior finality)?
- Did Judge Hernando commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying the motion to dismiss, rendering judgment on the pleadings, and issuing the writ of execution?
- Could the benefits of this Court’s decision in L-27526 (Angelita Vda. de Valera et al. v. Ofilada et al., 59 SCRA 96) be validly extended t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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