G.R. No. 175123 - Moldex Realty, Inc. vs. Spouses Villabona

Respondents (Eduardo, Ricardo, and Gilda Villabona) initiated the case by filing a Complaint on August 4, 1998, seeking the annulment of Transfer Certificate of Title (TCT) Nos. NT-250333 and NT-250334 registered in the name of Moldex Realty, Inc. (Moldex Realty).
The disputed properties were previously covered by Original Certificates of Title (OCT) Nos. 3322 and 3323.
Respondents claimed that they were the true owners—Eduardo of Lot No. 2346 and the spouses Ricardo and Gilda of Lot No. 2527—having acquired these properties via a Deed of Sale dated June 1, 1977 executed by their parents, Rafael and Ursula Villabona.

Respondents alleged that petitioner Moldex Realty, through its representative Levi P. Sayo, negotiated for the purchase of the subject lots in January 1996.
It was contended that Sayo obtained from respondent Ricardo the original copies of OCT Nos. 3322 and 3323, and that check payments corresponding to the sales were encashed by Moldex Realty and petitioner Anselmo Agero for different lots.
The respondents maintained that the titles were transferred through allegedly falsified Deeds of Absolute Sale executed on May 21, 1996, after the deaths of their parents (Rafael on June 3, 1993, and Ursula on October 17, 1990).

Respondents attached photocopies of the Deed of Sale with their parents, the TCTs (NT-250333 and NT-250334), the Certificates of Death of Rafael and Ursula, and the allegedly falsified Deeds of Absolute Sale to support their claims.
In contrast, petitioner Agero, in his Answer, denied any agency relationship with Moldex Realty regarding the purchase and refuted the encashment of any money.
Petitioner Moldex Realty contended that Sayo and Agero were acting as real estate brokers, and it presented its version that respondents had executed Deeds of Absolute Sale for a different sale price, supported by the issuance of a United Coconut Planters Bank check (dated May 13, 1996) which was duly deposited.

The trial commenced at the Regional Trial Court (RTC) of Cabanatuan City, with several hearings scheduled between October 2000 and November 2001.

The trial court initially allowed respondents to present evidence, with the first witness, Ricardo, testifying on October 5, 2000.
Numerous hearings were postponed or reset due to the repeated absences of respondents’ counsel (Atty. Cecilio Suarez) and, in some instances, the parties themselves.

The RTC Order on January 18, 2001, which deemed the respondents’ presentation of evidence as closed and terminated due to nonappearance.
Multiple resets on February 9, March 9, April 5, May 23, and subsequent dates, all largely attributable to the repeated absence of respondents’ counsel and the parties’ failure to proceed with an amicable settlement.
The RTC’s issuance of a decision on January 28, 2002, which declared the TCTs null and void and ordered damages against petitioners, despite unresolved issues regarding the submission of petitioners’ formal offer of evidence.

Petitioner Moldex Realty filed a Manifestation and subsequently a Motion for Reconsideration (February 11, 2002), arguing that the RTC erred by rendering a decision prior to the submission of its evidence and in violation of the procedural rules.
The RTC denied the Motion for Reconsideration on February 27, 2002, citing the lack of presentation of evidence by petitioners and the prolonged inactivity of respondents.
On appeal, the Court of Appeals (CA) affirmed the RTC’s decision, holding that petitioners had ample opportunity to present evidence and that the procedures followed were acceptable despite certain postponements.

Whether the RTC violated the due process rights of the petitioners by rendering a decision before petitioners had the opportunity to present their formal offer of evidence.
Whether the repeated resets and the premature closure of respondents’ presentation of evidence, due to the absence of their counsel, compromised the basic right to a fair hearing.

Whether the RTC’s procedure in handling the presentation of evidence—including the resetting of hearings and the subsequent rendering of a decision—was consistent with the provisions of Rule 30, Section 5 of the Rules of Court.
Whether the RTC appropriately considered the documents attached to the pleadings from both parties, or improperly favored the respondents’ attachments over those of the petitioners.

Whether the trial court should have continued the trial and resolved the pending Motion for Reconsideration rather than effectively terminating the presentation of evidence based on the promise of an amicable settlement.
The appropriateness of suspending the proceedings due to negotiations for compromise under Civil Code Articles 2029 and 2030.

Whether there were substantial factual disputes regarding the authenticity of the Deeds of Absolute Sale and the actual payment for the subject properties that necessitated a full trial rather than a summary judgment.
The impact of the conflicting accounts provided by the parties on the determination of title transfer and the legitimacy of the alleged transactions.