Case Digest (G.R. No. 167000)
Facts:
Government Service Insurance System (GSIS) v. Group Management Corporation (GMC) and Lapu‑Lapu Development & Housing Corporation (LLDHC), G.R. No. 167000 and G.R. No. 169971, June 8, 2011, Supreme Court First Division, Leonardo‑De Castro, J., writing for the Court.LLDHC was the registered owner of seventy‑eight (78) parcels in Marigondon, Lapu‑Lapu City. On February 4, 1974, LLDHC and GSIS entered into a Project and Loan Agreement whereby GSIS loaned P25,000,000 to LLDHC and took a real estate mortgage over the subject lots; after LLDHC allegedly defaulted, GSIS foreclosed, purchased the lots at public auction, and caused Transfer Certificates of Title (TCTs) to be issued in its name.
On November 19, 1979, GMC offered to buy the lots in installments; a Deed of Conditional Sale was executed by GSIS in February 1980 and later amended when the actual measured area proved smaller than originally represented. In April 1980 LLDHC filed an action in the Manila RTC (Civil Case No. R‑82‑3429) to annul the foreclosure. In November 1989 GMC sued GSIS in the Lapu‑Lapu RTC (Civil Case No. 2203‑L) for specific performance, claiming full payment and seeking a final deed of sale; LLDHC intervened.
After trial the Lapu‑Lapu RTC (February 24, 1992) ruled for GMC, ordering GSIS to execute the final deed and deliver the 78 titles, and awarding damages; motions to appeal by GSIS and LLDHC were dismissed by that RTC in December 1993. Separately, the Manila RTC (May 10, 1994) annulled GSIS’s foreclosure and ordered new titles to issue in favor of LLDHC upon payment, a decision later affirmed by the Court of Appeals (CA) in CA‑G.R. CV No. 49117.
LLDHC sought to annul the Lapu‑Lapu RTC judgment in the CA (CA‑G.R. SP No. 34696) and then in this Court (G.R. No. 118633); those petitions were dismissed, and the CA judgment dismissing annulment became final on January 28, 1995, with this Court affirming finality in its September 6, 1996 Resolution in G.R. No. 118633 (entry of judgment later certified final). Execution of the Lapu‑Lapu RTC judgment proceeded: writs of execution and several RTC orders between 1996–1997 directed transfer of titles to GMC and even directed the Register of Deeds to cancel GSIS titles and issue new ones in GMC’s name.
Complicating enforcement, a CA temporary restraining order (from LLDHC’s CA petition CA‑G.R. SP No. 44052) briefly hampered execution and allowed the Manila RTC writ to be implemented first in August 1997; ensuing litigation produced conflicting rulings from different CA divisions and this Court. In 1998 the CA ruled in CA‑G.R. SP No. 50650 largely in favor of GMC; this Court denied LLDHC’s review in G.R. No. 141407 (Sept. 9, 2002), finding the Lapu‑Lapu RTC decision final and binding on the parties other than those not in the Manila RTC case.
On March 11 and May 7, 2004 the Lapu‑Lapu RTC again ordered implementation of its 1992 judgment. LLDHC filed a CA petition (CA‑G.R. SP No. 84382) which the Special Nineteenth Division granted on September 23, 2005 annulling the March 11, 2004 order and issuing a permanent injunction. Separately GSIS filed CA‑G.R. SP No. 85096 seeking annulment of the March 11 and May 7, 2004 orders; the Twentieth Division of the CA dismissed GSIS’s petition on November 25, 2004 and denied reconsideration on January 20, 2005.
The two CA rulings were criticized as conflicting, and the matters were brought to this Court in consolidated Petitions for Review on Certiorari: G.R. No. 167000 (G...(Subscriber-Only)
Issues:
- Did the Manila RTC decision in Civil Case No. R‑82‑3429 constitute a supervening event that justifies altering or staying execution of the final Lapu‑Lapu RTC judgment in Civil Case No. 2203‑L?
- Are the September 23, 2005 CA decision in CA‑G.R. SP No. 84382 and GSIS’s petition in G.R. No. 167000 barred by res judicata?
- Is there a legal or physical impossibility preventing GSIS from complying with the Lapu‑Lapu RTC Orders of March 11, 2004 and May 7, 2004?
- Were LLDHC and GSIS guilty of forum shopping in initiating multiple, su...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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