G.R. No. 191723 - People vs. Las Pinas

Ireneo B. Zialcita, Jr. filed a petition before the Regional Trial Court of Quezon City seeking approval of a holographic will allegedly executed by his half-sister, Basilia Zialcita Vda. de Taningco, on February 24, 1984.
The trial court, acting as a probate court, appointed respondent Hortensia Z. Yuseco as temporary administratrix for the payment of taxes and to employ necessary measures for the preservation of the deceased’s estate.

Among the properties of the deceased was a house and lot located at No. 65 Santo Tomas St., Galas, Quezon City, covered by Transfer Certificate of Title (TCT) No. 33181.
The administration of the estate became complicated when respondent Yuseco, during tax payment arrangements, discovered the property had been sold prior to proper probate proceedings.

On May 9, 1988, Paulino Taningco, husband of the deceased, sold the subject property to Ireneo B. Zialcita, Jr., even though Zialcita, Jr. later admitted before the trial court that Paulino Taningco had died in February 1984, raising significant questions on the validity of the sale.
Subsequently, Ireneo B. Zialcita, Jr. sold the property to petitioners Gamaliel B. Palma and Eduardo A. Beltran for P1,000,000.00, as evidenced by the deed of absolute sale dated June 9, 1988, and the issuance of TCT No. 383686 and Tax Declaration No. 826 in the petitioners’ names.
On November 8, 1989, petitioners transferred the property to the Carmelite Theresian Missionaries, Inc., for which new documents—TCT No. PR-17857 and Tax Declaration No. C-030-00730—were issued.
On April 2, 1990, respondent Yuseco filed a motion before the trial court seeking to declare void all deeds of sale, tax declarations, and transfer certificates of title covering the subject property.

The trial court found that the property could not be transacted without the probate court’s approval since it was part of the deceased’s estate.
It held that the deed of sale dated May 9, 1988, between Paulino Taningco and Ireneo B. Zialcita, Jr. was fraudulent—a “clear forgery”—given the admission by Zialcita, Jr. regarding the death of Paulino Taningco.
The trial court observed that despite Zialcita, Jr. surrendering the owner’s duplicate copy of TCT No. 33181 on August 11, 1987, the document was later destroyed along with other records in a fire at Quezon City Hall on June 11, 1988.
Nonetheless, Zialcita, Jr. managed to acquire the property and transfer its ownership to the petitioners.
The trial court issued an order on June 5, 1990, nullifying the deeds of sale, tax declarations, and TCTs covering the property, and directed relevant offices (Register of Deeds, City Assessor, and City Treasurer) to expunge the invalid documents from their records.
Additionally, the trial court recommended the filing of criminal charges against Ireneo B. Zialcita, Jr., and petitioners Gamaliel B. Palma and Eduardo A. Beltran.

On June 22, 1990, the trial court denied the probate of Basilia Zialcita Vda. de Taningco’s holographic will because Ireneo B. Zialcita, Jr. failed to meet the requirement of establishing the authenticity of the handwriting by at least three credible witnesses as mandated under Article 811 of the New Civil Code, and due to evidence of the testatrix’s mental incapacity (senile dementia at the age of 90).
Petitioners, claiming they were innocent purchasers for value, argued that they had acquired the property from its registered owner (Zialcita, Jr.) whose title appeared genuine and had been verified with the Register of Deeds.
Petitioners later filed a motion for intervention and petition for relief on September 24, 1990, contending that they were deprived of their property without notice of the trial court’s order. However, the trial court refused to entertain these reliefs, noting that jurisdiction had been lost due to an existing petition for certiorari and mandamus before the Court of Appeals.

On April 3, 1991, the Court of Appeals initially set aside the June 5, 1990, trial court order based on two doctrines: a probate court lacked jurisdiction over title determination in estate properties equally claimed by third parties, and collateral attacks on Torrens titles were impermissible.
Subsequently, on May 31, 1991, upon respondent Yuseco’s motion for reconsideration, the Court of Appeals reversed its earlier decision and affirmed the trial court’s order, emphasizing:

The sales transactions occurred in 1988, after the filing of Sp. Proc. No. Q-43599 in 1984, confirming that the subject property was indeed part of the probate estate.
The trial court’s order had become final and executory and had been fully implemented when the property was sold to respondent Amigo Realty Development Corporation.

Petitioners’ subsequent motion for reconsideration was denied on August 5, 1991.

Whether the sale transactions involving the subject property, which was part of the deceased’s estate, could be validly effected without the probate court’s approval.

The issue delves into the jurisdiction of the probate court over real property disposition under estate administration.
It also questions whether the trial court had the authority to nullify transactions carried out without such approval.

The admissibility and effect of collateral attacks on Torrens titles under P.D. 1529.

Petitioners contended that their titles were protected as they were acquired in good faith as innocent purchasers for value.
The issue centers on whether the certificate of title, although later subjected to collateral attack, could be altered or invalidated in the absence of direct proceedings.

Whether the petitioners were deprived of their constitutional right to notice and hearing regarding the trial court’s issuance of the voiding order.
The effectiveness of the service of notice to petitioners, especially in light of the fact that they only learned of the order via a subpoena from the Provincial Prosecution Office.

Whether a judgment once fully executed and enforced can be reopened for reconsideration or amendment.
The legal significance of the property having been resold by the authorized probate order to a third party (Amigo Realty Development Corporation).