Case Digest (G.R. No. 227258)
Case Digest (G.R. No. 227258)
Facts:
Edna G. de Camcam and Benjamin M. Bitanga v. Daniel E. Vazquez, G.R. No. 227258, February 03, 2021, Third Division, Supreme Court, Inting, J., writing for the Court.On April 17, 2012, petitioners Edna G. de Camcam (Camcam) and Benjamin M. Bitanga filed a Complaint for reconveyance with a verified application for preliminary injunction/temporary restraining order against respondent Daniel E. Vazquez before the Regional Trial Court (RTC), Makati City (Civil Case No. 12-312), alleging ownership of a parcel covered by TCT No. S-92989 and challenging a series of transactions that ended with title in Vazquez’s name. The pleadings recount a 1981 mortgage to UCPB, foreclosure and UCPB’s acquisition of the property, a 1994 compromise enabling Camcam to redeem the property through Bitanga, a Deed of Sale from UCPB to Bitanga, and then a 1994–1995 Sale with Right of Repurchase (denominated as such) and a Guaranty executed by Camcam in favor of Vazquez to secure a P16 million loan.
Vazquez answered, averring that Bitanga sold the property to him with a one-year right of repurchase which Bitanga failed to exercise, resulting in the title’s transfer to Vazquez (TCT No. 213002). He pointed to Camcam’s admitted knowledge of the chain of transactions and to the notarized Guaranty in which Camcam warranted the validity of the sales, and raised defenses including waiver, prescription, and that the Sale with Right of Repurchase was not an equitable mortgage.
Vazquez moved for summary judgment (Aug. 7, 2013). The RTC (Branch 59, Makati) granted the Motion for Summary Judgment in a Resolution dated December 16, 2013, and denied petitioners’ motion for reconsideration in a Resolution dated April 7, 2014, concluding that petitioners’ admissions and documentary evidence established that there was no genuine issue of material fact and that Vazquez owned the subject property.
Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 103230). On January 26, 2016, the Court of Appeals affirmed the RTC’s grant of summary judgment, finding that Camcam’s admissions and the Guaranty foreclosed factual issues and noting the absence of any CA injunctive order barring the RTC from proceeding despite the pendency of a related CA special civil petition (CA-G.R. SP No. 129738). The CA denied reconsideration in a Resolution dated September 16, 2016.
Separately, petitioners had filed a Motion for Leave to Admit Amended Complaint in the RTC (Aug. 15, 2012), which the RTC denied (Nov. 5, 2012). They sought certiorari relief in the CA (CA-G.R. SP No. 129738), and on August 28, 2014 the CA granted the petition, directing the RTC to admit the amended complaint and try the case. That CA ruling was appealed to the Supreme Court in G.R. No. 216657, and in a Resolution dated August 24, 2016 the Supreme Court affirmed the CA decision; entry of judgment in G.R. No. 216657 was issued on June 19, 2017.
Petitioners filed the present Petition for Review on Certiorari under Rule 45 assailing the CA decision in CA-G.R. CV No. 103230 that affirmed the RTC’s grant of summary judgment; they argued the subsequent admission of their amended complaint rendered the summary judgment improper and that genuine issues remain for trial.
Issues:
- Did the Court of Appeals err in affirming the RTC’s grant of summary judgment when petitioners subsequently succeeded in having their amended complaint admitted by final appellate rulings?
- If the amended complaint was admitted, should the summary judgment have been set aside and the case remanded for trial on the amended complaint, or did genuine issues of material fact nonetheless justify the summary judgment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)