Facts:

The case involves Francisco Motors Corporation (FMC) as the petitioner and Antonio Raquiza as the respondent, with the decision rendered on October 23, 2006, by the Third Division of the Supreme Court of the Philippines (G.R. Nos. 117622-23). The dispute arose from events dating back to 1958, centering around the annulment of public auction sales of parcels of land owned by spouses Epifanio Alano and Cecilia Pading-Alano, with Raquiza serving as their attorney. The Alanos had agreed to pay Raquiza attorney’s fees equivalent to 30% of the properties in litigation. However, after he was unjustifiably dismissed, Raquiza was allowed to intervene in the civil cases to claim his fees.

The Court of First Instance of Rizal, Branch VI, on May 30, 1958, granted Raquiza’s motion to annotate his contractual right to fees on the relevant titling documents. However, by January 30, 1959, his lien was cancelled. A Joint Decision in December 1970 recognized his right to 30% of whatever rights t

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Facts:

Origin and Background of the Case

• The controversy originated in 1958 regarding the annulment of public auction sales of parcels of land located in San Jose and Norzagaray, Bulacan; Antipolo; and Las PiAas, Metro Manila.
• The subject properties were owned by spouses Epifanio Alano and Cecilia Pading-Alano.
• Antonio Raquiza acted as the lawyer for the Alano spouses in Civil Cases Nos. 2608 and 4622 on the understanding that he would receive attorney’s fees equivalent to 30% of the interests in the properties in litigation.
• After being dismissed without justifiable cause, Raquiza intervened in the civil cases to claim his attorney’s fees.

Initial Judicial Proceedings and Annotations

• On May 30, 1958, the Court of First Instance of Rizal, Branch VI, granted Raquiza’s motion to annotate his attorney’s lien on the titles involved in Civil Case No. 4622 (including TCT No. 56520 for a land parcel in Las PiAas).
• The annotation was later cancelled on January 30, 1959.
• On December 11, 1970, a Joint Decision of the CFI (Pasig, Branch 10) partially awarded Raquiza 30% interest in the rights of the Alano spouses in Natalia Realty, Inc., along with reimbursement for advances made.

Subsequent Title Transitions and Transactions

• Following the initial judicial proceedings, the Las PiAas property title underwent several changes: it was transferred from Miguel Campos to CPJ Corporation (a nominee of the Alano spouses) and later to the Alano spouses, with title numbers changed from TCT No. 56520 to TCT No. 190712 and subsequently to TCT No. 432260.
• On December 7, 1973, the Alano spouses executed a Deed of Sale with First Mortgage in favor of petitioner Francisco Motors Corporation (FMC).
• On January 21, 1974, both the Deed of Reconveyance and the Deed of Sale with First Mortgage were presented for registration, confirming the transfer of title eventually to FMC.

Enforcement Proceedings and Execution Efforts

• On January 17, 1980, the Special First Division of the Court of Appeals (CA) modified the lower court decision, clarifying that Raquiza was entitled to 30% pro indiviso interest in the reconveyed properties (with specified exceptions) and ordering reimbursements to him by the Alano spouses.
• Following the finalization of the CA decision on July 13, 1981, Raquiza pursued execution of his awarded fees by filing numerous motions and ex-parte petitions, including:
• Filing an Ex-Parte Motion for Execution on October 1, 1980.
• Filing motions for the issuance of a separate Transfer Certificate of Title in February and May of 1982, which were eventually granted by the trial court on October 8, 1982.
• Subsequent filings including supplemental motions for execution, corrections in title numbers, and motions for clarification on the non-surrender of the title by FMC.
• FMC, asserting its status as a good faith purchaser and disputing the validity of the attorney’s lien, opposed several of Raquiza’s motions.
• The trial court and later the CA issued orders including writs of execution and orders quashing such writs, which prolonged the dispute for nearly half a century.
• Raquiza eventually resorted to filing a petition for certiorari with the CA, which was remanded to the Supreme Court for review.
• Intervening events included FMC’s motion for reconsideration, the death of Raquiza in December 1999, and various procedural motions affecting the progress of the case.

Final Developments Prior to the Supreme Court Decision

• The CA rendered a decision on April 28, 1994, modifying earlier orders and addressing the enforcement of the attorney’s fee award against the disputed property.
• FMC filed the petition for review on January 2, 1995, which ultimately reached the Supreme Court for resolution.

Issue:

Whether the proper remedial action available to the private respondent (Raquiza) is the extraordinary writ of certiorari rather than an appeal.

• This includes the question as to whether the error concerning the trial court’s orders should be corrected through certiorari given the inadequacy of appeal as a remedy in the context of protracted litigation.

Whether the decision of the Court of Appeals in CA-G.R. Nos. 52159-60-R, which awarded attorney’s fees, can still be enforced by a mere motion under Section 6, Rule 39 of the Rules of Court despite the alleged lapse of the five-year execution period.

• Consideration is given to whether delays, some caused by actions of the debtor and procedural postponements, effectively suspended the statutory limitation period.

Whether the attorney’s fees awarded to Raquiza in the January 17, 1980 CA decision may be enforced/satisfied against the parcels of land acquired by FMC from the Alano spouses on December 7, 1973.

• Central to this issue is the determination of whether FMC, as an innocent purchaser for value, can be bound by an attorney’s lien that was not maintained or properly annotated on the title.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)