Case Digest (G.R. No. 178842)
Facts:
Rene H. Imperial and Nidsland Resources and Development Corporation v. Hon. Edgar L. Armes and Alfonso B. Cruz, Jr., G.R. Nos. 178842 and 195509, January 30, 2017, Supreme Court Third Division, Jardeleza, J., writing for the Court.The dispute arises from a Memorandum of Agreement dated September 24, 1993 between Julian C. Napal and Rene H. Imperial to organize Nidsland Resources and Development Corporation (NIDSLAND) and to contribute certain parcels of land (including Lot 15‑C, TCT No. 21026 — the Subject Property). Napal allegedly failed to convey the Subject Property to NIDSLAND and on July 24, 1996 purportedly sold it to Alfonso B. Cruz, Jr.; the sale was registered on August 27, 1996. Imperial filed a derivative action before the Securities and Exchange Commission (SEC) on July 30, 1996 (SEC LEO Case No. 96‑0004) and caused a notice of lis pendens to be annotated; that annotation was carried to the title later issued in Cruz’s name (TCT No. 43936).
The SEC, in a Decision dated November 10, 1998, declared the sale between Napal and Cruz void ab initio, ordered cancellation of Cruz’s title and directed conveyance to NIDSLAND; the Decision became final and was executed in January 1999, producing a Deed of Conveyance and new titles in NIDSLAND’s name. Napal unsuccessfully sought annulment under Rule 47 before the Court of Appeals (CA), which in August 1999 dismissed his petition for annulment of the SEC judgment as Rule 47 does not apply to SEC decisions.
On January 22, 2001 Cruz filed a petition in the Regional Trial Court (RTC), Legazpi City, to nullify the SEC Decision. The RTC initially dismissed motu proprio for want of jurisdiction; the CA, however, in October 2002 ruled the dismissal an abuse and remanded, directing the RTC to give due course. The matter saw a series of procedural rulings at the RTC — dismissals, denials, defaults set aside, rerafflings to Branches 3 and 4, and multiple motions by Imperial and NIDSLAND challenging jurisdiction and compliance with Rule 65’s reglementary period. RTC Branch 4 (Judge Edgar L. Armes) denied Imperial/NIDSLAND’s motions (Orders of Sept. 21 and Nov. 23, 2006), and the CA in resolutions of March 6, 2007 and July 3, 2007 dismissed Imperial/NIDSLAND’s certiorari petition attacking those RTC orders.
Imperial and NIDSLAND filed a Rule 45 petition (G.R. No. 178842) to the Court seeking reversal of the CA resolutions. Separately, RTC Branch 4 issued a decision on March 24, 2009 (the RTC Main Decision) declaring portions of the SEC Decision null and void as ...(Pro-only)
Issues:
- Did the Regional Trial Court, Branch 4, Legazpi City have jurisdiction to entertain Cruz’s petition to annul the SEC Decision?
- Did the SEC act with grave abuse of discretion in annulling the sale between Napal and Cruz, cancelling Cruz’s Torrens title(s) and ordering transfer to NIDSLAND, thereby rendering the SEC Decision void?
- May this Court directly cancel the Torrens certificates of title issued to NIDSLAND as having been issued pursuant to th...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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