Title
Galvez vs. Court of Appeals
Case
G.R. No. 157445
Decision Date
Apr 3, 2013
In Galvez v. Court of Appeals, the Supreme Court rules that a petition cannot be dismissed for lacking all pleadings if the attached documents adequately support the claims.
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Case Digest (G.R. No. 157445)

Facts:

  • Segundina A. Galvez (Petitioner) filed a case against the Hon. Court of Appeals, Spouses Honorio C. Montano and Susana P. Montano, and the Philippine National Bank (Respondents).
  • The case originated from a parcel of land in Barangay District II, Babatngon, Leyte, originally owned by Eustacio and Segundina Galvez.
  • Following their marital separation, Eustacio sold the property to their daughter Jovita on January 6, 1981, without Segundina's knowledge or consent.
  • Jovita mortgaged the property to the Philippine National Bank (PNB) on March 9, 1981, to secure a loan.
  • After Jovita defaulted, PNB extrajudicially foreclosed the property and acquired it as the highest bidder.
  • On June 10, 1992, the Montanos purchased the property from PNB.
  • Segundina refused to vacate the property, prompting the Montanos to file a suit for recovery of ownership and possession in the Municipal Trial Court (MTC) of Babatngon, Leyte.
  • Segundina argued that the sale from Eustacio to Jovita was null and void due to lack of her consent, rendering subsequent transactions void.
  • The MTC ruled in favor of the Montanos on February 4, 2000, stating the sale was merely voidable and that Segundina failed to annul it within the ten-year period prescribed by Article 173 of the Civil Code.
  • The MTC ordered Segundina to vacate the property and pay damages.
  • Segundina appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision on November 29, 2000.
  • After a denied motion for reconsideration on April 22, 2002, Segundina filed a petition for review with the Court of Appeals (CA).
  • The CA dismissed her petition on June 25, 2002, for failing to attach necessary pleadings and material portions of the record.
  • Segundina's motion for reconsideration was denied on February 6, 2003, leading her to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted Segundina's petition for review, reversed the CA's dismissal, and reinstated the case for resolution on the merits.
  • ...(Unlock)

Ratio:

  • The Supreme Court held that the failure to attach copies of pleadings and other material portions of the record should not result in the outright dismissal of a petition for review.
  • The Court emphasized that the CA should have assessed the sufficiency of the attachments provided by Segundina, which included certified true copies...continue reading

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