Case Digest (G.R. No. 147969) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Felicissima Galindo, Nestor Galindo, Beatriz Galindo, Catalina Galindo, Danilo Galindo, Librada Galindo, Cesar Galindo, and Juanita Galindo Rivera (collectively referred to as the Petitioners), filed a case against the heirs of Marciano A. Roxas, represented by Reginald S. Roxas (the Respondents), under G.R. No. 147969, with a decision date of January 17, 2005. The central issue dates back to the intestate death of Marciano A. Roxas on June 4, 1950, leaving behind his widow, Cirila Roxas, and their nine children. The dispute stems from an earlier action filed in the Court of First Instance (CFI) of Bulacan on April 14, 1955, by the heirs of Roxas against the heirs of Gregorio Galindo, demanding specific performance regarding Lot 1048, which was situated in Sta. Maria, Bulacan, and had an area of 48,089 square meters covered by Transfer Certificate of Title (TCT) No. T-2145.It was established that this lot had been possessed by Gregorio Galindo who had entered into an agreemen
Case Digest (G.R. No. 147969) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Death and Heirs of Marciano A. Roxas
- Marciano A. Roxas died intestate on June 4, 1950.
- Survived by his widow, Cirila Roxas, and nine children: Maximiano, Virginia, Benjamin, Eleazar, Elisa, Prescilla, Fortunato, Lydia, and Uriel (all surnamed Roxas); and the children of his predeceased son Vicente—Rosalinda, Vicente, Jr., and Sergio (all surnamed Roxas).
- Sale and Possession of Lot 1048
- Lot 1048, part of the Sta. Maria de Pandi Estate in Sta. Maria, Bulacan, measuring 48,089 square meters, was originally purchased by the late Gregorio Galindo.
- On July 5, 1911, the government (through the Acting Director of Lands) sold the lot to Gregorio Galindo for P859.50, payable in annual installments of P42.00.
- Upon Gregorio Galindo’s death on July 4, 1916, his heirs—Florencio, Felisa, Mercedes and the minor Urbano, as well as grandson Federico de Guzman—became involved in the disposition of the property.
- A document executed on December 1, 1916, by Florencio, Felisa, Mercedes, and Federico de Guzman (represented by his father Luis de Guzman) purportedly sold all of Gregorio Galindo’s rights in Lot 1048 to Marciano A. Roxas, with a special provision involving Lot 833 as security due to the minority of Urbano Galindo.
- Although possession and enjoyment of Lot 1048 were transferred immediately to Marciano A. Roxas, the document was not duly registered with the Bureau of Lands because Urbano was then a minor.
- In a subsequent development, Urbano Galindo, upon reaching majority, confirmed the validity of the sale by executing an affidavit on May 23, 1931.
- Payment, Title Issuance, and Administrative Proceedings
- Since taking possession, Marciano A. Roxas had been regularly paying the government installments, which were issued under Gregorio Galindo’s name, although for tax purposes the property was declared under Roxas’s name.
- On February 13, 1948, TCT No. T-2145 was issued by the Register of Deeds of Bulacan in the name of the legal heirs of Gregorio Galindo, due to the non-registration of the sale document caused by Urbano’s minority.
- Judicial Proceedings Prior to the Present Case
- On April 14, 1955, the heirs of Marciano Roxas filed an action for specific performance in the Court of First Instance (CFI) of Bulacan (Civil Case No. 1067) to compel the heirs of Gregorio Galindo to execute a deed of absolute sale transferring Lot 1048 to them.
- The trial revealed corroborative evidence including depositions and documentary exhibits demonstrating the sale and possession of the property by Marciano A. Roxas.
- The CFI rendered judgment on August 12, 1965, in favor of the heirs of Marciano Roxas, ordering the execution of the deed of absolute sale.
- The Court of Appeals (CA) affirmed the CFI decision on February 5, 1973, with the judgment becoming final and executory, although not enforced under Section 10, Rule 39 of the Rules of Court.
- Post-Judgment Developments and Extrajudicial Settlement
- Urbano Galindo subsequently died intestate.
- On December 16, 1997, Felicissima (widow of Urbano) and their children—Nestor, Juanita, Beatriz, Catalina, Danilo, Librada, and Cesar (all surnamed Galindo)—executed an Extrajudicial Settlement of the Estate of the deceased Urbano Galindo and/or Gregorio Galindo with Waiver of Rights.
- In the settlement, they adjudicated the undivided rights and interests in Lot 1048 to themselves and expressly waived claims over the lot in favor of Juanita Galindo Rivera.
- Subsequent to the settlement, Juanita Galindo Rivera secured a new Transfer Certificate of Title No. T-335593(M) after executing an affidavit of loss on TCT No. T-2145.
- The 1999 Complaint and Subsequent Motions
- On April 7, 1999, the heirs of Marciano Roxas, represented by Reginald S. Roxas, filed a complaint in the RTC of Bulacan seeking annulment of the extrajudicial settlement, cancellation of TCT No. T-335593(M), and damages.
- The complaint alleged that the extrajudicial settlement, the affidavit of loss, and the new title were void, being contrary to the final decision of the CFI and CA.
- The defendant (Juanita Galindo Rivera) moved to dismiss the complaint on two grounds: lack of legal capacity of Reginald S. Roxas to represent all heirs and the action being barred by the statute of limitations (ten-year rule) as applied to enforcing the CFI decision.
- The RTC denied the motion to dismiss on September 7, 1999, and again denied the defendant’s motion for reconsideration on November 26, 1999.
- Appellate and Certiorari Proceedings
- The defendants, along with the other Galindo family members, filed a petition for certiorari with the CA contending grave abuse of discretion by the trial court in denying their motions.
- The CA dismissed the petition for certiorari on April 4, 2001, finding that the petitioners failed to show that the RTC abused its discretion.
- The present petition for review on certiorari was filed, challenging both the dismissals and denials previously rendered.
Issues:
- Proper Party and Representational Capacity
- Whether the heirs of Marciano Roxas, represented by Reginald S. Roxas, had the legal capacity to sue and whether Reginald S. Roxas was properly authorized to represent all the heirs given the allegations in the complaint.
- Whether the petitioners (other than Juanita Galindo Rivera) who were not parties in the earlier RTC and CA proceedings are considered indispensable and proper parties in the current petition.
- Statute of Limitations and Nature of the Action
- Whether the action for quieting title based on the 1965 CFI decision (affirmed by the CA in 1973) has prescribed or whether it remains valid given that actions to quiet title are imprescriptible.
- Whether the complaint, arguably an action for enforcing a constructive trust or quieting title, falls within the ten-year limitation period for enforcement of a final and executory decision.
- Impleading of Indispensable Parties
- Whether the failure to join certain Galindo family members (and other co-owners, such as the children of Vicente Roxas) as parties-defendants invalidated the earlier RTC and CA proceedings.
- Whether the absence of these indispensable parties renders subsequent orders and judgments null and void.
- Grave Abuse of Discretion
- Whether the RTC committed a grave abuse of discretion in denying the motion to dismiss for lack of capacity and for alleged prescription.
- Whether such alleged errors could be corrected notwithstanding the procedural misjoinder of parties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)