Case Digest (G.R. No. 167284)
Facts:
The Estate of Soledad Maninang and the Law Firm of Quisumbing Torres, petitioners, v. The Honorable Court of Appeals, Spouses Salvacion Serrano Ladanga and Agustin Ladanga, and Bernardo Aseneta, G.R. No. 167284, July 06, 2011, Supreme Court First Division, Del Castillo, J., writing for the Court.In 1975 Clemencia Aseneta (Clemencia), through her adopted son and judicially-appointed guardian Bernardo Aseneta, filed a reconveyance suit (Civil Case No. Q-20128) against Spouses Salvacion and Agustin Ladanga to annul alleged deeds of sale over two Quezon City properties (the Diliman and the Cubao properties). Clemencia died in 1977 and Bernardo was substituted as plaintiff. After prolonged proceedings, the trial court on February 24, 1995 ordered reconveyance of both the Diliman (TCT No. 197624) and Cubao (TCT No. 204090) properties to Clemencia’s estate.
Separately, estate settlement (Probate Case) arose between Soledad Maninang (represented by petitioner law firm Quisumbing Torres, “QT”) and Bernardo. By a November 5, 1992 Decision Based on Compromise Agreement, the parties agreed on distribution of the estate, including a clause awarding interests in “any other real properties, known or unknown” (Aseneta 37.5%, ALGR 12.5%, Maninang 35%, QTE 15%).
Bernardo alleged that in 1987 he and the spouses Ladanga compromised the Reconveyance Case as to the Cubao property and agreed to sell it to a third party (no copy of that compromise appears in the record). The spouses Ladanga appealed the trial court’s 1995 reconveyance decision to the Court of Appeals (docketed CA-G.R. CV No. 51242). Petitioners sought to join Bernardo as appellee by a Motion for Joinder of Additional Parties (filed September 2, 1996) claiming a 50% undivided interest in the Cubao property under the Probate compromise; Bernardo and the spouses Ladanga opposed.
The Court of Appeals, without acting on petitioners’ joinder motion, on November 7, 2000 affirmed the trial court insofar as it related to the Diliman property (TCT No. 197624). The spouses Ladanga elevated that portion to this Court (G.R. No. 145874); this Court affirmed on September 30, 2005. Petitioners, learning in 2001 of the CA’s November 7, 2000 Decision, filed a Motion for Partial Reconsideration before the CA seeking nullification or denial of any purported compromise between Bernardo and the spouses Ladanga over the Cubao property.
The CA issued two contested resolutions: a June 1, 2004 Resolution refusing to act on petitioners’ Motion for Partial Reconsideration because of the pendency before the Supreme Court of a petition for review filed by Agustin Ladanga; and a Decem...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion amounting to lack or excess of jurisdiction by refraining from acting on petitioners’ motions and thereby denying them the opportunity to litigate their claimed interest in the Cubao property in the appeal (i.e., did petitioners have a right to adjudicate their Cub...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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