G.R. No. 238762 - Heirs of Punongbayan vs. St. Peter's College, Inc.

On November 18, 1965, plaintiffs Fabio Masangya and Jose Abayon filed a complaint for partition of real estate against the respondents.
The dispute centered on the rightful ownership of a parcel of land, which later became the subject of a judicial partition proceeding.

Fabio Masangya, one of the original plaintiffs, died on December 21, 1971.
During the proceedings on January 7, 1972, counsel for the plaintiffs, Atty. Rufo Venus, moved for the substitution of the deceased plaintiff.
A motion for substitution, dated February 15, 1972, was filed, and the court, through an order signed by District Judge Bienvenido Ejercito, granted the substitution.
The deceased was replaced by his heirs – Federico, Arturo, Rodrigo, Carpio, Aelasar (all surnamed Masangya), and Maura M. de Jose – who now stood as petitioners.

Trial on the merits took place with Atty. Venus presenting three witnesses on behalf of Jose Abayon and the substituted parties.
On September 21, 1982, the trial court rendered a decision dismissing the petitioners’ complaint and declared the respondents as the lawful owners of the disputed land.

Dissatisfied with the trial court’s decision, petitioners appealed to the Court of Appeals.
The Court of Appeals affirmed the trial court’s ruling on December 9, 1986.
An Entry of Final Judgment was issued on October 21, 1987 upon the respondents’ motion, based on the absence of an appeal from the petitioners.

After the final judgment, a writ of execution was issued at the motion of the respondents.
Petitioners filed a “Motion to Recall Order on Issuance of Writ of Execution” on two grounds:

The trial court denied the motion on April 26, 1988, and also denied a subsequent motion for reconsideration on June 29, 1988.

Petitioners sought certiorari from the Supreme Court, challenging both the substitution of parties and the notice of judgment.
They argued that the absence of timely objection and the fatal error in substitution rendered the litigation void and the judgment non-final and non-executable.

Whether the substitution of the deceased plaintiff, Fabio Masangya, by his heirs was legally proper and effective.
Whether the subsequent trial proceedings, appeal, and ultimately the judgment were affected by any defect in the substitution.

Whether sending the notice of judgment to the deceased counsel (Atty. Rufo Venus) amounted to a lack of effective or due notice.
Whether the petitioners were sufficiently notified through alternative means, ensuring their right to be heard under due process.

Whether petitioners’ active participation in the proceedings and failure to raise these issues at an earlier stage precluded them from later challenging the substitution and notice.
Whether the doctrine of estoppel bars the petitioners from contesting the jurisdictional issues raised in their petition.