G.R. No. 172538 - Esperida vs. Jurado Jr.

A contested case was initiated in the Court of First Instance of Manila (Civil Case 45778) involving a foreclosure of a real estate and chattel mortgage.
The case involved appellant Isabel Ocampo (formerly Isabel O. Vda. de Chi Chioco) as the mortgagor and appellee Ignacio Domalanta as the mortgagee.
The mortgage pertained to a property located in Tanza, Cavite, where the appellant had mortgaged the land, which was also subject to a first mortgage in favor of the Philippine National Bank.
Judgment was rendered ordering the mortgagor to pay P2,000.00 plus 1% interest per month from December 5, 1958 until full payment, and P500.00 as attorneys’ fees.
The judgment additionally directed that upon failure to pay within ninety days, the mortgaged properties should be sold at public auction.

The judgment debt remained unpaid, prompting the court to issue a writ of execution on Domalanta’s motion.
On May 8, 1962, the sheriff sold the mortgaged land (32,558 square meters) at public auction to the highest bidder, who was, in fact, the appellee Ignacio Domalanta, for P3,537.00.
Following the sale, Domalanta sought confirmation of the sale, and the court confirmed the sale on June 2, 1962, despite opposition from the appellant.

After the June 2, 1962 order became final, the appellant initiated a separate suit (Civil Case N-496 in the Court of First Instance of Cavite) seeking to annul the confirmed sheriff’s sale.
The appellant’s grounds for annulment centered on:

Alleged improper notification regarding the foreclosure sale by the Provincial Sheriff.
The contention that the property was sold at a price “very much lower than the actual market value” which was argued to be unconscionably low and shocking to the conscience.

The earlier objection raised by the appellant during the foreclosure proceedings had raised identical points (lack of notice and undervaluation), but these were dismissed by the court as unsupported by evidence.
The lower court dismissed the annulment suit on November 9, 1962, with prejudice and imposed costs against the plaintiff-appellant, a decision that was reaffirmed on a motion for reconsideration on November 21, 1962.

The confirmation of sale in the foreclosure proceedings became final and binding as no appeal was taken.
The subsequent action to annul the sheriff’s sale was based on issues that were already presented and litigated in the earlier foreclosure suit, leading to the application of res judicata principles.

Whether the confirmation of a sheriff's sale in a judicial foreclosure proceeding, already confirmed by the court and not subject to appeal, precludes a subsequent action by the judgment debtor to annul the sale on grounds that were already raised during the foreclosure proceedings.
Whether the appellant’s claims of improper notice and unconscionable sale price raised in the annulment suit are sufficient to overcome the conclusive effect of the earlier confirmation order.