Title
Heirs of Casino, Sr. vs. Development Bank of the Philippines, Malaybalay Branch, Bukidnon
Case
G.R. No. 204052-53
Decision Date
Mar 11, 2020
Spouses defaulted on a DBP loan, leading to foreclosure. Son claimed ownership post-transfer, but SC ruled res judicata barred his claim, affirming prior judgment.

Case Digest (G.R. No. 204052-53)
Expanded Legal Reasoning Model

Facts:

  • Background and Transactional History
    • On December 28, 1975, spouses Baldomero and Leonarda Casiao obtained a loan of P130,000.00 from the Development Bank of the Philippines (DBP) secured by a real estate mortgage over three parcels of land located in the municipalities of Valencia and Lantapan, Bukidnon.
    • The mortgage was evidenced by Original Certificates of Title (OCT) Nos. P-372 and P-1652 and Tax Declaration (TD) No. 01915.
  • Foreclosure and Registration Process
    • Due to the Spouses Casiao’s failure to settle their loan obligation, DBP initiated extrajudicial foreclosure proceedings on March 24, 1977.
    • In the auction sale, DBP made the winning bid and was issued a Sheriff Certificate of Sale on July 17, 1977, which was then registered with the Register of Deeds on September 16, 1977.
    • Upon failure of the Spouses Casiao to redeem the properties within the prescribed redemption period, DBP consolidated the title in its name, cancelling the OCTs and TD while replacing them with Transfer Certificates of Title (TCT) Nos. T-13478 and T-13479 and a new tax declaration (TD No. 06596).
  • Subsequent Legal Proceedings Involving the Casiao Family
    • Baldomero Casiao later filed a complaint before the Regional Trial Court (RTC Br. 8, Malaybalay, Bukidnon) for annulment of the real estate mortgage and foreclosure proceedings, quieting of title, redemption, and damages (Civil Case No. 1465).
    • After due proceedings, the RTC Br. 8 rendered a decision on August 3, 1990 dismissing the complaint.
    • Baldomero’s appeal of the dismissal was affirmed in a May 30, 1995 decision by the Court of Appeals (CA) and, subsequently, his petition for review on certiorari was denied by the Supreme Court in a July 10, 1996 resolution.
  • Transfer of Rights and Filing of a New Complaint
    • On April 25, 1994, Baldomero executed a document known as the Kasabotan, wherein he relinquished to his son, Aurio T. Casiao, all rights over the three properties, including a 120-hectare lot at Sitio Kibulay, Barrio Cawayan, Municipality of Lantapan.
    • On January 13, 1997, DBP sold the Kibulay property to Green River Gold, Inc.
    • After the sale, DBP and Green River filed an ex-parte petition with RTC Br. 8 for a writ of possession over the Kibulay property; however, enforcement was allegedly hampered by threats from armed men employed by Aurio.
    • Aurio subsequently filed an affidavit of third-party claim on March 20, 1997, asserting ownership and possession of the Kibulay property.
    • On March 21, 1997, Aurio initiated an action for quieting title before the RTC Branch 10 in Malaybalay City, asserting that he was the true, lawful, and absolute owner of a property in Bukidnon.
    • DBP responded by asserting that Aurio’s complaint was barred by res judicata, as ownership over the subject property had already been conclusively determined in the prior foreclosure proceedings (Civil Case No. 1465), and further argued that the complaint was defective for failing to implead Green River Gold, with whom DBP had transacted the sale.
  • Procedural History and Interventions
    • Green River Gold, Inc. intervened by filing an answer adopting DBP’s affirmative defenses, including the absence of a cause of action, laches, prescription, and issues regarding proper jurisdiction of the RTC Br. 10 vis-à-vis RTC Br. 8’s issued writ of possession.
    • DBP and Green River later filed an ex-parte petition for an alias writ of possession in Civil Case No. 1465, which RTC Br. 8 granted on December 3, 2001.
    • In Civil Case No. 2685-97, RTC Br. 10 rendered a judgment on July 4, 2006, declaring that the subject property claimed by Aurio was different from that being claimed by DBP and Green River, and held that the earlier decision in Civil Case No. 1465 was not binding on Aurio or his heirs since they were not parties to that case.
    • The RTC Br. 10 also directed Green River to vacate the premises and ordered joint attorney’s fees and litigation expenses to be paid by DBP and Green River to Aurio.
    • Subsequent motions resulted in the denial of reconsideration by RTC Br. 10 but granted the motion for execution pending appeal on January 4, 2007.
    • DBP and Green River appealed separately, with DBP also filing a Petition for Certiorari under Rule 65 alleging grave abuse of discretion by RTC Br. 10 for granting execution pending appeal.
  • Court of Appeals Findings and the Instant Petition
    • On February 16, 2012, the CA granted the appeals of respondents (DBP and Green River), vacated the RTC Br. 10 judgment, and ruled that Aurio’s complaint lacked merit and was barred by res judicata.
    • The CA also upheld DBP’s petition for certiorari, holding that RTC Br. 10 committed grave abuse of discretion in granting the motion for execution pending appeal.
    • On October 11, 2012, the CA denied Aurio’s Motion for Reconsideration, reaffirming that including Civil Case No. 1465 in the statement of facts was proper given its intimate relation to the instant case.
    • Ultimately, Aurio filed the petition before the Supreme Court, raising four main assignments of error regarding factual mischaracterization, the evidentiary value of tax declarations, the application of res judicata, and the alleged grave abuse of discretion in granting execution pending appeal.

Issues:

  • Factual Presentation
    • Whether the Court of Appeals erred in its statement of facts by focusing on the 1975 loan and foreclosure background instead of the quieting of title case (Civil Case No. 2685-97) which is the main subject on appeal.
  • Evidentiary Value of Tax Declarations
    • Whether the CA erred in holding that tax declarations, by themselves, are not conclusive evidence of ownership, thereby negating Aurio’s cause of action.
  • Application of Res Judicata
    • Whether the CA incorrectly applied the doctrine of res judicata by including the antecedent Civil Case No. 1465, and whether the issues and parties in that case are identical to those in the instant quieting of title action.
  • Grave Abuse of Discretion
    • Whether the CA erred in holding that the RTC Br. 10 committed grave abuse of discretion in granting a motion for execution pending appeal based on the alleged advanced age of Patricia (Aurio’s spouse), and whether such justification meets the “good reasons” threshold.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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