Case Digest (G.R. No. L-25843) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Elsa D. Medado as the petitioner and the heirs of the late Antonio Consing, represented by Dr. Soledad Consing, as respondents. In 1996, the Spouses Meritus Rey and Elsa Medado (Spouses Medado) executed deeds of sale with assumption of mortgage with the estate of Antonio Consing for property known as Hacienda Sol in Cadiz City. The sale covered lands under several titles and included an assumption of the estate's loan with Philippine National Bank (PNB). After the sale, the estate offered the same lots to the government under the Department of Agrarian Reform Voluntary Offer to Sell (VOS) program. In 2000, the estate, via Soledad Consing as administratrix, sued the Spouses Medado for rescission and damages claiming failure to meet sale conditions, docketed as Civil Case No. 00-11320. Concurrently, Land Bank of the Philippines (LBP) issued certificates of deposit and agrarian reform bonds compensating the estate for the lot sales under VOS. Fearing that LBP wou Case Digest (G.R. No. L-25843) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- In 1996, Spouses Meritus Rey Medado and Elsa Medado (Spouses Medado) purchased from the estate of the late Antonio Consing (Estate of Consing) parcels of land in Cadiz City known as Hacienda Sol through Deeds of Sale with Assumption of Mortgage.
- The purchased properties were covered by OCT No. P-498, TCT No. T-31275, TCT No. T-31276, and TCT No. T-31277.
- Spouses Medado assumed the estate's loan with Philippine National Bank (PNB) as part of the purchase.
- After the sale, the Estate of Consing offered the lots to the government under the Department of Agrarian Reform's Voluntary Offer to Sell (VOS) program.
- On November 22, 2000, the Estate of Consing filed with the Regional Trial Court (RTC), Branch 44, Bacolod City, Civil Case No. 00-11320 for rescission and damages against Spouses Medado, PNB, and the Register of Deeds of Cadiz City, alleging failure to fulfill the agreement conditions.
- During the pendency of Civil Case No. 00-11320, Land Bank of the Philippines (LBP) issued a certificate of deposit for cash and agrarian reform bonds as compensation for the VOS-covered lots to the Estate of Consing.
- Spouses Medado feared LBP would release the proceeds to the Estate, but claimed entitlement to the proceeds due to their purchase agreement.
- Consequently, Spouses Medado filed Civil Case No. 797-C before the RTC, Branch 60, Cadiz City, seeking injunctions to:
- Restrain LBP from releasing the VOS proceeds balance to the Estate of Consing.
- Compel LBP to release the proceeds to them.
- On March 9, 2007, the RTC, Branch 60, issued an order granting Spouses Medado's application for preliminary prohibitory and mandatory injunctions to maintain the status quo and direct LBP to release the VOS proceeds to them after posting a bond of P5,000,000.00.
- The heirs of the late Antonio Consing filed a petition for certiorari with the Court of Appeals (CA) challenging the RTC order, alleging violation of rules on litis pendentia and forum shopping, and sought the dismissal of the injunction case.
- They explained their failure to file a prior motion for reconsideration by stating that LBP already released the proceeds, rendering their motions for reconsideration moot.
- The CA, on September 26, 2008, nullified and set aside the RTC order and dismissed Civil Case No. 797-C, ruling the Spouses Medado’s injunction suit violated the rule against forum shopping due to the pendency of Civil Case No. 00-11320.
- The CA's Resolution dated January 21, 2009 denied the motion for reconsideration filed by Spouses Medado.
- Elsa Medado petitioned the Supreme Court (SC), raising issues regarding the admissibility of the CA petition, the absence of a motion for reconsideration before filing certiorari, and alleged violation of the rule against forum shopping.
Issues:
- Whether the CA correctly admitted the petition for certiorari despite alleged deficiencies in its verification and certification against forum shopping.
- Whether the CA properly admitted the petition even though no motion for reconsideration of the RTC's order was filed before resorting to a petition for certiorari.
- Whether the CA correctly ruled that the rule against forum shopping was violated by filing an injunction case during the pendency of the rescission and damages case.
- (Raised in respondent's comment) Whether Elsa Medado erred in not joining her husband as a party in the petition, considering the action affects conjugal property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)