Title
Heirs of Maravilla vs. Tupas
Case
G.R. No. 192132
Decision Date
Sep 14, 2016
Property dispute over Boracay land; SC ruled Boracay Decision a supervening event, voiding sale as land was inalienable, preventing execution of prior judgment.
A

Case Digest (G.R. No. 192132)

Facts:

  • Parties and property
    • HEIRS OF ZOSIMO Q. MARAVILLA, NAMELY, ZOSIMO W. MARAVILLA, JR., YVETTE MARAVILLA AND RICHARD MARAVILLA, REPRESENTED BY ZOSIMO W. MARAVILLA, JR., PETITIONERS claimed ownership under a Deed of Sale dated February 8, 1975 executed by the late Zosimo Maravilla and the late Asiclo S. Tupas.
    • PRIVALDO TUPAS, RESPONDENT and other heirs of Asiclo S. Tupas maintained occupation and possession of portions of the disputed land in Diniwid, Barangay Balabag, Malay, Aklan, a parcel of approximately 1,000 hectares assessed under Tax Declaration No. 1304 and more particularly described in the pleadings.
  • Trial and appellate proceedings leading to final judgments
    • Petitioner filed Civil Case No. 4338 for quieting of title with recovery of possession and damages before RTC, Branch 9, Kalibo, Aklan; RTC rendered a decision declaring the deed of sale valid over one-half portion (about 5,000 sq. m.), ordered delineation and partitioning of portions, removal of cottages in plaintiff’s portion, modification of muniments, refund of P7,000 to defendants, and payment by plaintiff of P10,000 attorney’s fees.
    • Petitioner appealed; the Court of Appeals (CA) in a Decision dated August 28, 1996 set aside the RTC decision and declared Zosimo Maravilla owner of 10,000 sq. m. undivided share in the 36,382 sq. m. parcel, directed partition and turnover of possession; Special Proceedings No. 39517 was dismissed.
    • Petitioner filed a separate partition case on October 21, 1999 before RTC, Branch 6, Kalibo; RTC rendered judgment on March 31, 2003 declaring the one-hectare portion in the sketch plan as plaintiff’s rightful share, ordering restoration of possession, and awarding agreed monthly compensation of P5,000 starting in 1990 until possession was restored.
    • Respondent appealed the March 31, 2003 decision; the CA dismissed the appeal on April 13, 2007 on the ground of *res judicata*, concluding identity of facts and evidence with the prior quieting of title case.
  • Execution motion, intervening national decision, and CA relief
    • Petitioner filed a Motion for Execution of the March 31, 2003 RTC decision on October 31, 2008.
    • While the motion was pending, this Court issued the consolidated decision in The Secretary of the Department of Environment and Natural Resources (DENR), et al. v. Yap, et al. and Sacay, et al. v. the Secretary of the DENR, et al. (the Boracay Decision) on October 8, 2008, ruling that Boracay Island is state-owned except for lands already covered by existing titles.
    • RTC, Branch 6 granted the motion for execution in a Resolution dated February 2, 2009; it denied respondent’s motion for reconsideration in an Order dated April 7, 2009.
    • Respondent filed a petition for certiorari with the CA assailing the RTC’s grant of execution and arguing that the Boracay Decision is a supervening event rendering the deed of sale void because the land was part of the public domain and inalienable at the time of the sale....(Subscriber-Only)

Issues:

  • Primary legal question presented
    • Whether the Supreme Court’s decision in The Secretary of the Department of Environment and Natural Resources (DENR), et al. v. Yap, et al. and Sacay, et al. v. the Secretary of the DENR, et al. (the Boracay Decision) constitutes a supervening event that prevents execution of the final and executory March 31, 2003 RTC judgment in favor of petitioners.
  • Subsidiary questions
    • Whether the CA gravely departed from the accepted and usual course of judicial proceedings in setting aside RTC orders granting execution of a final judgment.
    • Whether,...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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