G.R. No. 184466 - Crispino vs. Tansay

Respondent Anatolia Tansay, who was twice widowed, established her residence in Oroquieta, Misamis Occidental in 1947 and later moved to Cebu City.
During her time in Oroquieta, Anatolia met the then-single 20‐year-old Zenaida Capili, whom she took in and treated as her own child.
After relocating to Cebu City, Anatolia acquired a 3,107 sq. m. property known as the Tansay Compound and subdivided it into three lots (Lot No. 1048-A-1, 1048-A-2, and 1048-A-3).
In 1957, Anatolia constructed her abode on a portion of Lot No. 1048-A-3, around which the familial relationship with Zenaida and her family grew closer, with Zenaida’s children affectionately addressing her as “nanay.”

A deed of sale on July 6, 1981, purporting to transfer Lot No. 1048-A-1 in favor of Zenaida Echaves.
A deed of sale on July 11, 1989, purportedly transferring Lot No. 1048-A-3 in favor of Luz Anatolia E. Crispino and Caridad C. Echaves.

Despite these transactions, evidence before the trial showed that none of the parties paid any monetary or valuable consideration for the transfers, and the deeds were rendered invalid as they were intended merely to constitute the parties as trustees of the properties rather than effect an actual sale.

In 1991, after Zenaida discovered that the original titles were missing, she filed a petition for reconstitution of the certificates of title, which was granted by the Regional Trial Court (RTC) of Cebu City.
Concurrently, Anatolia filed Civil Case No. CEB-14547 for revocation of trust, declaration of nullity of transfer, and cancellation of titles.
On February 16, 1996, the RTC rendered its decision:

Declaring Anatolia as the lawful owner of Lot No. 1048-A-1 and Lot No. 1048-A-3.
Ordering the cancellation of the titles issued to Zenaida, Luz Anatolia, and Caridad, thereby reinstating Anatolia’s title to the respective lots.

Zenaida, Luz Anatolia, and Caridad appealed the RTC’s decision before the Court of Appeals.
During the pendency of the appeal, Anatolia died on August 11, 2001 and was substituted by her only known legal heir, Lilian Tan Yap.
On August 16, 2001, the petitioners filed an Urgent Motion to Remand Records of the Case for the Re-Opening of Trial, seeking to introduce an affidavit titled “Confirmation of Previous Sales” allegedly executed by Anatolia on January 15, 1998.
The motion argued that the document confirming the sales of Lot No. 1048-A-1 and Lot No. 1048-A-3 was newly discovered evidence that could prevent a grave miscarriage of justice.
However, the Court of Appeals, through a Resolution dated July 25, 2006, denied the motion by treating it as a motion for new trial under Rule 53 of the Rules of Court.
Subsequently, on January 24, 2007, the Court of Appeals rendered its decision affirming the RTC’s ruling, and the petitioners’ subsequent motion for reconsideration was denied on August 28, 2008.
Finally, the petitioners raised their issue before the Supreme Court through a Petition for Review on Certiorari, challenging both the evidentiary ruling and the manner in which the motion to remand was treated.

Whether the Court of Appeals erred in treating the petitioners’ motion to remand as a motion for new trial under Rule 53 of the Rules of Court.
Whether the Court of Appeals’ power to introduce additional evidence is confined solely to motions based on newly discovered evidence, as required under its internal rules and Section 9 of Batas Pambansa Blg. 129 (as amended by Republic Act No. 7902).

Whether an interlocutory order—specifically, the Resolution denying the motion to remand—can be challenged directly through an appeal or requires a special civil action for certiorari under Rule 65 of the Rules of Court.