G.R. No. 182984 - Nocom vs. Camerino

Case Digest (G.R. No. 182984)
Expanded Legal Reasoning Model

Facts:

Background and Prior Case (G.R. No. 161029)

Respondents Oscar Camerino, Efren Camerino, Cornelio Mantile, Nolasco Del Rosario (deceased, represented by Mildred Del Rosario), and Domingo Enriquez were tenants tilling parcels of land formerly owned by Victoria Homes, Inc., planted with rice and corn. These lands were covered by TCT Nos. 289237, S-6135; S-72244; and 289236, S-35855.
On February 9, 1983, without informing the tenants/respondents, Victoria Homes, Inc. sold the said lots to Springsun Management Systems Corporation (SMSC) for ₱9,790,612. Registered titles were issued in favor of SMSC.
SMSC mortgaged the lots to Banco Filipino (BF) for loans totaling ₱11,545,000 but defaulted. Banco Filipino foreclosed extrajudicially and was adjudged highest bidder.
On May 10, 2000, SMSC redeemed the lots from Banco Filipino.
On March 7, 1995, the respondents filed Civil Case No. 95-020 against SMSC and BF for prohibition, certiorari, reconveyance, damages, and injunction.
On January 25, 2002, RTC Muntinlupa Branch 256 found respondents were tenants since 1967 and authorized them to redeem the subject lots for ₱9,790,612 within 180 days. The court ordered SMSC to deliver titles upon payment and vacate possession and also awarded attorney's fees.
The Court of Appeals affirmed with modification in September 2003, declaring respondents as tenants entitled to redemption but deleting attorney's fees for lack of basis.
The Supreme Court affirmed this ruling on January 19, 2005, reiterating the right of respondents as agricultural tenants to redeem the land from SMSC.

Current Case Facts (G.R. No. 182984)

On December 3, 2003, petitioner Mariano Nocom gave respondents each Philtrust Bank Manager’s Checks amounting to ₱500,000, allegedly for their "inchoate and contingent rights" over the subject lots, which they sold to him.
On December 18, 2003, respondents with their spouses executed an Irrevocable Power of Attorney (SPA) appointing petitioner to sell, transfer, mortgage, and dispose of said properties, comply with court redemption orders, and receive all proceeds, among others. The SPA was notarized by their counsel, Atty. Arturo S. Santos.
On July 21, 2005, respondents filed a Motion for Execution in Civil Case No. 95-020 for the Register of Deeds to divest SMSC of title and vest it on respondents. Respondents deposited ₱9,790,612 plus commissions with RTC, Branch 256.
The RTC granted the motion, canceled SMSC’s TCTs, issued new TCTs in respondents’ names, and ordered the SPA to be annotated in the memorandum of encumbrances.
On October 24, 2005, respondent Oscar Camerino filed Civil Case No. 05-172, "Petition to Revoke Power of Attorney," seeking annulment of the SPA, turnover of titles, and payment of attorney’s fees.
Respondent alleged they were asked by counsel Atty. Santos to sign a document purportedly urgently needed for proceedings but later found to be the SPA granting petitioner ownership rights. He claimed no intention to appoint petitioner to dispose of the land and that consideration was not properly explained; he filed an Affidavit of Adverse Claim annotated on titles.
Petitioner answered, claiming the SPA was voluntarily signed, coupled with interest, and that respondents received ₱500,000 each as consideration for selling contingent rights; the SPA cannot be revoked unilaterally. He prayed for dismissal and damages compensation.
Respondents Efren Camerino, Cornelio Mantile, and Mildred Del Rosario filed a Complaint-in-Intervention alleging fraud, misrepresentation, undue influence by both petitioner and Atty. Santos, and that the SPA is void as a champertous contract contrary to law and public policy.
The RTC of Muntinlupa City, Branch 203, admitted intervention, granted summary judgment annulling the SPA for being contrary to law under Agrarian Reform Code Sec. 62, and void as champertous contract since petitioner was attorney of respondents and arranged a deal for title acquisition. The court ordered return of payments and delivery of titles back to respondents.
Petitioner filed motion for reconsideration, which was denied. He appealed to the Court of Appeals (CA).

Court of Appeals Ruling

CA affirmed RTC’s decision and dismissed petitioner’s appeal for lack of jurisdiction because the case raised questions of law proper for Rule 45 petition for review to the Supreme Court, not Rule 41 appeal.
CA denied petitioner’s motion for reconsideration.

Issues:

Whether the Court of Appeals erred in dismissing petitioner’s appeal for lack of jurisdiction.
Whether the CA erred in upholding the Summary Judgment even though petitioner raised genuine issues of fact.
Whether the CA was correct in not voiding the Summary Judgment for failure to implead indispensable party, i.e., Atty. Arturo S. Santos.
Whether the CA erred in not dismissing Civil Case No. 05-172 for non-payment of correct docket fees considering the nature of the case.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 182984) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 182984) Expanded Legal Reasoning Model

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Case Digest (G.R. No. 182984)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 182984)
Expanded Legal Reasoning Model