G.R. No. 132537 - Gomez vs. Sta. Ines

On June 17, 1986, Mary Josephine Gomez and Eugenia Socorro Gomez-Salcedo filed a complaint for damages before the RTC of Pasig against Marietta dela Cruz Sta. Ines.
The complaint alleged that Marietta, entrusted with managing and supervising 25,087 square meters of rice land (together with Transfer Certificate of Title [TCT] No. 47082) belonging to the deceased Purificacion dela Cruz Gomez, had failed to deliver an accounting or return of the TCT despite repeated demands.

During the pre-trial conference, Marietta and her counsel failed to appear, leading to her being declared in default.
On January 24, 1989, the Pasig RTC rendered judgment against Marietta, ordering:

The delivery of the owner’s copy of TCT No. 47082 to Mary Josephine and Socorro.
Payment of various damages – moral, actual (compensatory), exemplary (corrective) – and attorney’s fees.

After the judgment became final and executory, a writ of execution was issued by the Pasig RTC.
A parcel of land with improvements, covering 432 square meters (TCT No. T-55314 in Marietta’s name) was levied upon by the Sheriff of Nueva Vizcaya.
The land was sold at a public auction on August 25, 1992, with Mary Josephine emerging as the highest bidder; the sale was duly registered on September 17, 1992.

On July 12, 1993, a separate complaint for annulment of the auction sale was filed before the RTC of Bayombong, Nueva Vizcaya, by Hinahon Sta. Ines together with Noel, Roel, and Jannette Sta. Ines.
The respondents (plaintiffs in the annulment case) alleged that the house and lot, sold at public auction, is their family residence and is exempt from execution under Section 12(a), Rule 39 of the Rules of Court and Article 155 of the Family Code.
Mary Josephine moved to dismiss the annulment complaint based on three grounds:

The Nueva Vizcaya RTC denied Mary Josephine’s Motion to Dismiss on November 10, 1993, holding that:

The petitioners (respondents in the annulment case) were proper third-party claimants since they were not parties to the Pasig RTC case but had their rights affected by the execution proceedings.
Execution proceedings, unlike the trial proper, do allow independent actions to protect rights (under Section 17 of Rule 39 and the Judiciary Reorganization Act).

On December 1, 1993, respondents filed a Motion for Reconsideration, which was granted through an Order dated January 28, 1994, by the Nueva Vizcaya RTC. The rationale was that jurisdiction over execution proceedings should reside with the Pasig RTC.
Respondents filed a subsequent Motion for Reconsideration of the dismissal Order, which was denied on March 15, 1994.
The respondents then appealed the dismissal Order to the Court of Appeals, raising errors regarding:

The alleged improper exercise of jurisdiction by the RTC being in Nueva Vizcaya instead of the Pasig RTC.
The contention that respondents were not legitimate third-party claimants.

In their Appellee’s Brief, petitioners challenged the jurisdiction of the appellate court, arguing that the issues raised were purely questions of law, subject to the exclusive review of the Supreme Court.
The Court of Appeals, on March 29, 1996, reversed the dismissal Order by holding that:

As third-party claimants, respondents could avail themselves of the remedies provided in Section 17, Rule 39.
The allegation that the property was a family residence exempt from execution gave rise to an issue that involved factual determinations of beneficiary status.

Petitioners later filed a Petition for Review on Certiorari before the Supreme Court, raising the following assignments of errors:

The erroneous ruling by the Court of Appeals regarding the jurisdiction of the RTC of Nueva Vizcaya.
The mistaken finding that respondents were proper third-party claimants.
The error in assuming appellate jurisdiction over issues claimed to be purely questions of law.

Whether the Nueva Vizcaya RTC had jurisdiction to hear and decide the annulment complaint concerning the execution sale of the house and lot.
Whether there was a conflict between the jurisdiction of the Pasig RTC (which rendered the original judgment and issued the writ of execution) and that of the Nueva Vizcaya RTC.

Whether the respondents (the husband and children of Marietta) possessed legal capacity to file the separate action as beneficiaries of a family home under Article 154 of the Family Code.
Whether respondents could be considered proper third-party claimants given that they were not parties to the original Pasig RTC case.

Whether the questions raised (particularly regarding jurisdiction and exemption under Article 155 of the Family Code) are purely legal issues not requiring fact-finding, or whether they inherently involve questions of fact that must be resolved in a separate judicial action.

Whether the house and lot, as the alleged family residence, were exempt from execution under Article 155 of the Family Code, considering that the debt arose from actions committed before the family home was constituted by law.