Title
Macedonio vs. Ramo
Case
G.R. No. 193516
Decision Date
Mar 24, 2014
Petitioner sought rescission, then specific performance, after discovering property liens. SC ruled dismissal improper, remanded for merits, prioritizing justice over technicalities.

Case Digest (G.R. No. 193516)
Expanded Legal Reasoning Model

Facts:

  • Overview of the Case
    • This case involves a Petition for Review on Certiorari filed by Vilma Macedonio challenging the dismissal with prejudice of Civil Case No. 7150-R by the Regional Trial Court (RTC) of Baguio City, Branch 6.
    • The petition arises out of multiple related proceedings involving alleged wrongful acts by Catalina Ramo concerning a transaction for a portion of an unregistered lot, and subsequent conflicting actions including a DENR protest.
  • Civil Case No. 5703-R
    • Facts of the Transaction and Filing
      • On October 29, 2003, petitioner and respondent Ramo entered into an agreement for the sale of 240 square meters––part of a 637-square meter unregistered lot in Brgy. Sto. Rosario Valley, Baguio City.
      • Petitioner paid P850,000.00 as earnest money against an agreed sale price of P1,700,000.00. A “Deed of Sale with Mortgage to Secure Payment of Price” was executed.
      • Ramo assured petitioner that the subject property was free from liens and encumbrances; however, a tax declaration later showed existing liens (a judicial levy connected to another case and a mortgage to ARGEM).
    • Allegations and Subsequent Proceedings
      • Petitioner's complaint sought rescission of the sale and damages (actual, moral, exemplary, attorney’s fees, and expenses) for Ramo’s alleged misrepresentations.
      • The parties attempted to settle the dispute with an agreed compromise that eventually failed to materialize, leading the trial court to set the case for further proceedings and later dismiss it for failure to prosecute.
      • Numerous orders were issued: a motion for reconsideration, orders extending time for compromise, and eventual termination of the case on October 23, 2006.
    • Developments Involving the Property
      • Despite the pending case, Ramo secured a Sales Patent and an Original Certificate of Title issued on October 16, 2006.
      • In June 2007, Ramo subdivided the property into three lots and transferred them to individual respondents (the Pedros, Marquez, and the Balanags) through different legal instruments, but no portion was transferred to petitioner.
    • Additional Petitioner’s Actions
      • In February 2008, petitioner moved for an order directing Ramo to refund the P850,000.00 advance payment. Ramo opposed, stating the matter was moot due to petitioner’s non-compliance with previous orders.
      • Through subsequent exchanges and admissions by Ramo (including a June 29, 2009 letter), the dispute persisted regarding whether Ramo should refund the amount paid.
  • DENR Protest
    • On December 2, 2009, petitioner filed a written Protest with the DENR-Cordillera Administrative Region.
    • The protest sought investigation into Ramo’s acquisition of the subject property and prayed for the nullification of Ramo’s Sales Patent and subsequent titles, proposing that petitioner, as a qualified bidder, be allowed to acquire the property.
    • No remedial action had been taken on the protest as of the ruling.
  • Civil Case No. 7150-R
    • Filing and Claims
      • On April 21, 2010, petitioner filed Civil Case No. 7150-R with RTC, Branch 6, seeking specific performance, annulment of documents and titles, and damages.
      • The complaint prayed for:
        • Rescission and nullification of the trust and sale agreements between Ramo and the other individual respondents.
ii. Annulment of the certificates of title issued to the Pedros, Marquez, and the Balanags. iii. Annulment of a mortgage contract executed between the Balanags and BPI Family Savings Bank, Inc. iv. A rescission alternative for a refund of petitioner’s payments with interest, along with moral, exemplary damages, and attorney’s fees.
  • Respondents’ Opposition and RTC’s Ruling
    • Respondents argued that petitioner committed forum shopping by filing multiple actions on substantially the same cause of action and thus violated the certification rules against forum-shopping.
    • On July 20, 2010, the RTC dismissed Civil Case No. 7150-R with prejudice based on:
      • Violation of Section 5, Rule 7 of the 1997 Rules of Civil Procedure (failure to disclose the existence of the earlier case and DENR Protest).
ii. The occurrence of forum shopping and litis pendentia.
  • Petitioner’s Position
    • Petitioner contended that the first case (Civil Case No. 5703-R) was terminated without being tried on the merits, thereby leaving her free to pursue the second action (Civil Case No. 7150-R).
    • She further argued that the DENR Protest involved a different cause of action (fraud and misrepresentation in obtaining the sales patent) and should not bar Civil Case No. 7150-R.

Issues:

  • Whether filing multiple actions in relation to the same disputed transaction constitutes forum shopping, particularly when the claims (rescission in Civil Case No. 5703-R and specific performance/annulment in Civil Case No. 7150-R) and the DENR protest arise from distinct legal causes.
    • Determination of whether the failure to disclose concurrent actions (the earlier case and the protest) violates the procedural requirements.
    • Analysis of whether these actions amount to an unlawful splitting of a single cause of action.
  • Whether the RTC erred in dismissing Civil Case No. 7150-R with prejudice solely on the technical ground of non-compliance with certification rules, thus precluding a trial on the merits.
    • Consideration of the fact that the earlier case was terminated without adjudication on the merits.
    • Evaluation of whether a rigid application of forum-shopping rules would deny substantive justice.
  • Whether the failure of petitioner to fully comply with the certification requirements under the 1997 Rules should automatically bar the merits of her claim, or if justice demands that the underlying facts and evidentiary admissions be given due weight.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
Unlock Full Case Digest

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.

About Privacy Terms