Case Digest (G.R. No. 188029)
Facts:
The case involves Arturo C. Calubad as the petitioner and Billy M. Aceron and Oliver R. Soriano as respondents. The events leading to the case began in April 1992 when Aceron and Soriano entered into an unnotarized Deed of Conditional Sale for a parcel of land in Quezon City, valued at P1.6 million. The property was covered by Transfer Certificate of Title (TCT) No. 15860, registered in the names of Francisco R. Soriano and Rosa R. Soriano, who had donated the property to their son, Oliver. The Deed of Conditional Sale stipulated that Oliver would reconstitute the title and transfer ownership to Aceron, who was allowed to take possession of the property upon paying P300,000.
In October 1992, the title was reconstituted, but when Aceron demanded the execution of a Deed of Absolute Sale, Oliver informed him of the cancellation of their agreement. Consequently, on October 19, 1993, Aceron filed a complaint against Oliver in the Regional Trial Court (RTC) of Quezon City, seeki...
Case Digest (G.R. No. 188029)
Facts:
Background of the Case:
- In April 1992, Billy M. Aceron (Aceron) and Oliver R. Soriano (Oliver) entered into an unnotarized Deed of Conditional Sale for a parcel of land in Quezon City, covered by Transfer Certificate of Title (TCT) No. 15860, registered in the name of Oliver's parents, Spouses Soriano. The property was later donated to Oliver.
- The Deed of Conditional Sale stipulated that Oliver would reconstitute the title and transfer ownership to Aceron upon payment of P1.6 million. Aceron was allowed to take possession of the property after paying P300,000.
Dispute Over the Sale:
- In October 1992, the title was reconstituted, and Aceron demanded the execution of a Deed of Absolute Sale. Oliver refused, claiming Aceron failed to pay the full amount.
- On October 19, 1993, Aceron filed a complaint before the Regional Trial Court (RTC) of Quezon City, Branch 96, seeking the execution of the Deed of Absolute Sale and damages.
RTC Decision:
- On December 26, 1996, the RTC ruled in favor of Aceron, ordering Oliver to execute the Deed of Absolute Sale and pay attorney's fees. Aceron appealed, but the Court of Appeals (CA) affirmed the RTC's decision on February 18, 2002, which became final and executory on August 5, 2003.
Execution of Judgment:
- On July 4, 2003, the RTC granted Oliver's motion for a writ of execution. On August 5, 2003, the Register of Deeds issued TCT No. N-253373 in Oliver's name.
- Oliver informed Aceron of the rescission of the Deed of Conditional Sale and demanded that Aceron vacate the property.
Mortgage to Calubad:
- On December 17, 2003, Oliver obtained a loan of P1.6 million from Arturo C. Calubad (Calubad) and mortgaged the property covered by TCT No. N-253373 as security.
Aceron's Omnibus Motion:
- On January 9, 2004, Aceron moved for the execution of the RTC's December 26, 1996 decision. The RTC granted the motion on March 5, 2004, and Aceron deposited P970,000 with the court.
- Oliver failed to deliver the title, claiming it was already mortgaged to Calubad. Aceron filed an Omnibus Motion on October 3, 2004, seeking the transfer of the property to his name, free from liens and encumbrances.
RTC Resolution:
- On December 13, 2004, the RTC granted Aceron's Omnibus Motion, divesting Oliver of ownership, ordering the issuance of a new title to Aceron, and declaring the mortgage and foreclosure sale null and void.
Calubad's Petition:
- Calubad filed a petition under Rule 65 before the CA, challenging the RTC's December 13, 2004 resolution, arguing that he was not a party to the case and was not given notice. The CA dismissed the petition on March 14, 2006, and denied reconsideration on March 27, 2007.
- Calubad then filed a petition for annulment of judgment under Rule 47, which the CA dismissed on September 19, 2007, and denied reconsideration on May 29, 2009.
Issue:
Whether the CA had jurisdiction to:
- Cancel the annotations of the real estate mortgage and certificate of sale in favor of Calubad on TCT No. N-253373.
- Declare the real estate mortgage and foreclosure sale null and void.
- Declare Calubad as a mortgagee in bad faith, despite Calubad not being a party to Civil Case No. Q-93-18011 and the absence of a notice of lis pendens on TCT No. N-253373.
Whether the CA correctly dismissed Calubad's petition for annulment, finding that he had other available remedies besides a petition for annulment under Rule 47.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the CA's dismissal of Calubad's petition for annulment of judgment, ruling that the RTC's resolution was valid and binding on Calubad as a successor-in-interest to Oliver. The Court emphasized the finality of judgments and the need to resolve disputes conclusively.