G.R. No. 160409 - Landcenter Construction and Development Corp. vs. V.C. Ponce, Co., Inc.

The subject property is the Fourth Estate Subdivision, Area I, located in Barrio Kaybiga, ParaAaque City, covering 107,047 square meters.
Originally titled in the name of respondent V.C. Ponce Co., Inc. under Transfer Certificate of Title (TCT) No. 97084.
A subdivision plan (LRD Psd-23194) was prepared on November 2, 1962 by V.C. Ponce, subdividing the property into 239 lots.
As a result, TCT No. 97084 was partially canceled and replaced by TCT Nos. 110001 to 110239 covering the smaller lots.

In January 1974, respondent Vicente C. Ponce mortgaged several lots—including those covered by TCT No. 97084—against the Philippine Commercial International Bank (PCI Bank) for the amount of P1,327,000.00.
PCI Bank was not notified that the property had been subdivided into 239 lots.
Respondents’ failure to pay resulted in the foreclosure and subsequent auction sale, where PCI Bank emerged as the highest bidder.
Respondents filed a complaint challenging the extra-judicial foreclosure sale; the Court of First Instance (CFI) dismissed the complaint, and its decision was later affirmed by the Court of Appeals (CA) and finally by the Supreme Court.

Respondents initiated another complaint in the RTC of Pasig City for reconveyance of 54 lots and refund of overpayments involving unused letters of credit.
During the pendency of this case, respondents annotated a notice of lis pendens over the 54 lots and saw the detachment of TCT No. 97084 from the Register of Deeds (RD) in Pasig with subsequent transfer to Makati.
On June 25, 1976, the RD of Makati canceled TCT No. 97084 and issued TCT No. S-30409 in the name of PCI Bank.
On April 27, 1987, PCI Bank sold the subject property (along with other properties) to petitioner Landcenter Construction and Development Corporation (Landcenter); this sale was registered in the RD of ParaAaque.
TCT No. S-30409 was later canceled and replaced by TCT No. 123917 in Landcenter’s name.

On March 13, 1989, respondent Vicente produced an allegedly fake deed of assignment purportedly signed by Manuel Ponce, president of Landcenter, which transferred two road lots and the subject property from Landcenter to the respondents.
Landcenter then filed a Complaint on November 11, 1997, before the RTC of ParaAaque City seeking:

Annulment of the deed of assignment on the ground of forgery and lack of valid authorization by its Board of Directors.
Cancellation of the affected Transfer Certificates of Title and damages.

Amidst the litigation, respondents filed motions including one to enjoin Landcenter from disposing of the subject property.
On September 21, 1999, the RTC granted Landcenter’s motion ordering:

Removal of sales ad boards and structures on the subject property within five days.
Cancellation of TCT Nos. 110001 to 110239 in the respondents’ names.

Respondents filed successive motions for reconsideration and for dismissal based on jurisdictional arguments and the adequacy of docket fees, resulting in a series of conflicting orders from the RTC.
On June 9, 2000, following multiple motions and orders, the RTC:

Granted Landcenter’s motion for reconsideration, thereby upholding its right over the subject property and affirming the cancellation of TCT Nos. 110001 to 110239.
Denied respondents’ motion for reconsideration.

Subsequently, respondents filed a Petition for Certiorari under Rule 65 before the CA challenging the three RTC orders (dated September 21, May 8, and June 9, 2000).
On October 30, 2001, Landcenter moved to dismiss the petition for certiorari, citing its withdrawal of the complaint in Civil Case No. 97-0532.
Respondents countered that despite the termination of the RTC case, the RTC had not vacated all the orders affecting their rights.

The CA ruled on May 6, 2003, that Landcenter’s withdrawal restored the parties’ rights to their original positions but left unresolved some RTC orders.
The CA annulled the specific RTC order directing the cancellation of TCT Nos. 110001 to 110239 and ordered the cancellation of TCT No. S-30409 in the name of PCI Bank.
The other issues raised by the petitioners were dismissed as moot and academic because a new title had already been issued and the pertinent civil case had been terminated.

Whether the petition for certiorari filed under Rule 65 by the respondents can prosper based on the withdrawal of Landcenter’s complaint from Civil Case No. 97-0532.

The question centers on whether the withdrawal of the complaint effectively nullifies or impairs the respondents’ rights as set in motion by the RTC orders.

Whether the trial court judge acted without or in excess of her jurisdiction, or with grave abuse of discretion, when issuing the challenged orders dated September 21, May 8, and June 9, 2000.

This issue interrogates the scope of judicial authority and whether the orders were beyond the prudence of the RTC.

Whether the withdrawal of the complaint by the petitioner prejudiced the respondents’ rights.

It involves analyzing the effect of withdrawal on prior judicial orders and the restoration of parties’ positions as if no suit had been filed.

Whether the CA erred in “partially granting” the respondents’ petition for certiorari by annulling some RTC orders while dismissing other issues as moot or academic.

This considers if such a selective remedy is consistent with established jurisprudence and procedural fairness.