G.R. No. 74817 - Estoesta Sr. vs. Court of Appeals

Petitioners Simeon Estoesta, Sr. and Lucia Estoesta, owners of the subject property, originally obtained rights to a house and lot located at 54-A Legaspi Street, Project 4, Quezon City.
The property was initially awarded to them by the Philippine Homesite and Housing Corporation (PHHC) in 1953.
In 1967, after transferring to Davao City, the petitioners left the occupancy of the property to their daughter, Trinidad Estoesta, who was handling payments of monthly amortizations to PHHC on their behalf.
For convenience in transaction with PHHC, the petitioners acceded to their daughter’s request to have the title transferred into her name.
Upon full payment of the property’s value, PHHC executed a Deed of Sale in favor of Trinidad Estoesta and issued Transfer Certificate of Title (TCT) No. 145066 on September 19, 1969, with a restrictive annotation limiting further sale or transfer without PHHC’s written consent for five (5) years.

In 1973, upon learning that Trinidad Estoesta offered the property for sale, the petitioners demanded a re-transfer of title by executing a deed of sale in their favor.
On February 11, 1974, Trinidad Estoesta executed a deed of absolute sale in favor of the petitioners, satisfying conditions that included the petitioners’ payment (of P10,000.00 within one year) and assumption of Trinidad’s GSIS loan secured by the property.
For the account of Trinidad, petitioners made payments to GSIS amounting to P5,800.00 from February 5, 1974 to August 5, 1974.
Before the lapse of the five (5) year period—and without PHHC’s consent—on August 5, 1974 Trinidad Estoesta executed another Deed of Sale in favor of private respondent Luis Villamor for a consideration of P17,000.00.
It was alleged that Luis Villamor bought the property in bad faith given his knowledge of the occupancy irregularities.

On October 7, 1974, the petitioners initiated a case for annulment of the sale of the property, alleging the subsequent sale to Villamor was void.
Private respondent Luis Villamor filed his Answer with a counterclaim on October 22, 1974, asserting the validity of the sale and claiming good faith as a buyer, while also attacking the earlier sale between petitioners and Trinidad as fictitious and obtained by force and intimidation.
Trinidad Estoesta filed motions which were denied, and her answer was eventually stricken from the record following her default.
The trial court, after extended hearings, rendered its decision on August 15, 1978, in which it ruled in favor of the petitioners by:

Nullifying the sale executed by Trinidad Estoesta to Luis Villamor.
Ordering the cancellation of TCT Nos. 202855 and 145066 with the issuance of a new title in the petitioners’ names.
Awarding costs and attorney’s fees against the defendants.

On October 30, 1984, the Court of Appeals (CA) promulgated a decision contrary to the trial court by:

Upholding and declaring the deed of sale executed by Trinidad Estoesta to Luis Villamor as valid.
Ordering the petitioners to surrender possession of the subject premises.
Imposing moral damages, attorney’s fees, and the payment of other litigation costs against the petitioners.

Multiple motions for reconsideration were filed by both parties in the trial court (e.g., motions on October 3, 1978; October 5, 1978; and later October 24, 1979) and were subsequently denied.
The private respondent filed a notice of appeal on August 7, 1979 along with a motion for extension, though this filing was later found to be untimely.

The petitioners moved to set aside the trial court’s order extending the time to file the record on appeal, arguing that the appellate process was tainted by the late filing.
The trial court subsequently dismissed the appeal for being filed out of time on November 13, 1979, later reconsidering this dismissal with an order on January 3, 1980, and finally, on December 16, 1980 ordered the transmittal of the amended record on appeal to the Court of Appeals.
The CA’s decision of October 30, 1984 and its denial of the petitioners’ motion for reconsideration on October 29, 1985 prompted the petitioners to elevate the matter to the Supreme Court.
The Supreme Court, after a petition for review on certiorari in G.R. No. 72662 was denied on January 6, 1986, rendered its judgment on February 17, 1986.
In a bid to enforce the CA ruling, the trial court issued a writ of execution on May 12, 1986 and denied the petitioners’ motions to quash the writ and for reconsideration in its orders dated May 21 and May 29, 1986 respectively.
Petitioners raised two principal grounds in their certiorari, prohibition, and mandamus petition:

The respondent trial court judge was accused of grave abuse of discretion by enforcing the writ of execution emanating from a decision that was allegedly a patent nullity.
The same judge was also accused of acting without or in excess of jurisdiction by denying the petitioners’ urgent motion to quash the writ.

Whether private respondent’s appeal was perfected within the reglementary period as mandated by the Rules of Court (noting that the appeal period was 30 days at the time, reduced later to 15 days under B.P. 129)?
Whether the late filing of the notice of appeal, appeal bond, and record of appeal necessarily rendered the appellate proceedings void?

Whether the trial court’s decision dated August 15, 1978 became final and executory by operation of law due to the failure to perfect the appeal on time.
Whether the appellate court had jurisdiction to review or alter a judgment that had already become final and executory.

Whether the trial court’s issuance of a writ of execution to enforce the appellate court’s decision, which purportedly arose from a void or null appeal, constitutes grave abuse of discretion.
Whether denying the petitioners’ application to quash the writ of execution was proper given the underlying timely finality of the August 15, 1978 decision.

Whether, as a matter of law, a void judgment confers any rights or obligations, and how this principle affects the enforceability of subsequent orders based thereon.