Case Digest (G.R. No. 147148)
Facts:
In Rene Manuel R. Jose v. Elizabeth Quesada-Jose et al. (G.R. No. 249434, March 15, 2023), petitioner René Manuel R. Jose, son of the late Domingo and Emilia Jose, assails the June 25, 2018 Decision and September 20, 2019 Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 107444, which reversed the Regional Trial Court (RTC) of Antipolo City’s July 16, 2015 Order dismissing Civil Case No. 08-8406 for litis pendentia. In 1978, Domingo and Emilia purportedly sold their 23-hectare Antipolo property to Cynthia Cuyegkeng (petitioner’s wife) for ₱65,000 by deed of sale, and title was later registered in her name (TCT No. N-50023). In 1996, Philippine Export and Foreign Loan Guarantee Corporation (now TIDCORP) sued Domingo before RTC Makati; to settle that case, Domingo, Cynthia, and petitioner agreed to a compromise whereby 109,234 sqm. of the Antipolo property was conveyed to TIDCORP and registered under a new title (TCT No. R-19951), while the remaining portions (TCT Nos. R-1Case Digest (G.R. No. 147148)
Facts:
- Antecedents and Property Transactions
- Spouses Domingo and Emilia Jose owned a 23-hectare Antipolo property under TCT No. N-50023. On November 3, 1978, they executed a deed of sale in favor of their son’s wife, Cynthia Cuyegkeng Jose, for ₱65,000.00; on September 11, 1980, TCT No. N-50023 was reissued in Cynthia’s name.
- In 1996, TIDCORP sued Domingo as a solidary debtor. To settle, Domingo (with spouse Emilia’s consent) and Cynthia agreed to cede 109,234 sq.m. of the Antipolo property to TIDCORP by compromise. The Court of Appeals approved the agreement. The property was subdivided, the original TCT cancelled, and three new titles issued on January 28, 2004: R-19951 to TIDCORP (109,234 sq.m.), and R-19952 (104,081 sq.m.) and R-19953 (19,627 sq.m.) to Cynthia and Rene.
- Collection Case (RTC Manila, Civil Case No. 05-11400)
- On December 1, 2005, petitioners Rene Manuel R. Jose and Cynthia filed for ₱120 million and damages, alleging an oral agreement with Domingo to pay fair value of the ceded land. Upon Domingo’s death, his son Luis Mario Jose was substituted.
- The RTC Manila conducted a full-blown trial on whether the 1978 sale was simulated. On December 22, 2014, it held the sale valid and Torrens title indefeasible, awarding ₱53.3 million plus 6% interest. The CA and this Court affirmed on appeal.
- Annulment Case (RTC Antipolo, Civil Case No. 08-8406)
- While the collection case was pending, on February 13, 2008, Luis, representing his parents’ heirs, filed for annulment of the 1978 sale and cancellation of TCT Nos. R-19952 and R-19953.
- On July 16, 2015, the RTC Antipolo granted Rene and Cynthia’s motion to dismiss for litis pendentia, finding the same issue had been decided in RTC Manila.
- Appeals and Petition
- The CA reversed the dismissal on June 25, 2018, holding no litis pendentia and equating the collection case’s ownership finding to a provisional ejectment ruling. A motion for reconsideration was denied on September 20, 2019.
- Petitioners filed this Petition for Review on Certiorari (G.R. No. 249434) seeking reinstatement of the RTC Antipolo dismissal.
Issues:
- Whether the action for annulment of sale and cancellation of titles is barred by litis pendentia.
- Whether the CA erred in treating RTC Manila’s conclusive finding on ownership as merely provisional, akin to an ejectment case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)