Case Digest (G.R. No. 120265)
Facts:
Antonio Navarro v. Metropolitan Bank & Trust Company, G.R. No. 165697; Clarita P. Navarro v. Metropolitan Bank & Trust Company, G.R. No. 166481, August 04, 2009, Supreme Court Third Division, Peralta, J., writing for the Court.Petitioners are Antonio Navarro and Clarita P. Navarro; respondent is Metropolitan Bank & Trust Company (MBTC). Antonio and Clarita were married in 1968 and during the marriage acquired three parcels in Alabang, Muntinlupa City covered by TCT Nos. 155256–155258, which, however, were registered in the name of “Antonio N. Navarro... married to Belen B. Navarro.”
In 1998 MBTC caused judicial foreclosure of a mortgage purportedly constituting Antonio as mortgagor; MBTC was the sole bidder at the December 1998 public auction and obtained a certificate of sale. In 1999 Clarita filed Civil Case No. 99‑177 in the Regional Trial Court (RTC) of Muntinlupa — an action for declaration of nullity of mortgage and foreclosure and reconveyance with damages — alleging that the properties were conjugal and were registered and mortgaged without her knowledge; Belen was not impleaded. MBTC moved to dismiss for laches; the RTC denied the motion. MBTC petitioned the Court of Appeals in CA‑G.R. SP No. 55780, which dismissed Civil Case No. 99‑177 on the ground of laches; that decision became final with no appeal or motion for reconsideration.
On April 17, 2002 Clarita filed a substantively similar suit, Civil Case No. 02‑079 in the same RTC, this time seeking nullity of the TCTs and reconveyance, impleading Antonio, Belen, MBTC and Registers of Deeds. MBTC moved to dismiss, invoking the prior dismissal and alleging waiver/abandonment; the RTC denied the motion (Order, Nov. 8, 2002) and later denied reconsideration. MBTC then filed a petition for certiorari and prohibition with the Court of Appeals (CA‑G.R. SP No. 76872), alleging grave abuse of discretion. Meanwhile a compromise between Antonio and Clarita was executed and approved by the trial court, leaving MBTC as the remaining defendant. The Court of Appeals granted MBTC’s petition and, in its July 8, 2004 Decision, reversed the RTC and ordered dismissal of Civil Case No. ...(Subscriber-Only)
Issues:
- Does the prior final dismissal of Civil Case No. 99‑177 on the ground of laches bar the refiling of the same claim in Civil Case No. 02‑079 (i.e., is the second suit precluded by the finality of the earlier judgment and the rules on dismissal and res judicata)?
- Can laches be applied to bar an action to declare the nullity of a mortgage/contract given petitioners’ contention that...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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