G.R. No. L-53692 - Ramos vs. Pablo

Original Agreement and Transfer of Rights: On July 31, 1957, plaintiffs Guillermo N. Pablo and Primitiva C. Cruz entered into an agreement with Pedro del Rosario/Del Rosario Realty to purchase a parcel of land in Quezon City. The rights under this agreement were later assigned to Socorro A. Ramos on June 16, 1959.

Execution of Deed of Sale: On March 28, 1963, Socorro A. Ramos executed a Deed of Absolute Sale in favor of the plaintiffs, transferring the land to them. However, the deed was subject to the condition that it would not be registered until the resolution of a pending Supreme Court case (G.R. No. L-16797) involving Rodrigo Enriquez and Socorro A. Ramos.

Undisclosed Mortgage and Foreclosure: Unknown to the plaintiffs, the land was already mortgaged to Rodrigo Enriquez, who had filed a foreclosure action on April 29, 1959. The Supreme Court ruled against Socorro A. Ramos on March 1, 1963, leading to the foreclosure and transfer of the land to Rodrigo Enriquez, who later sold it to Maria Cristina F. Villadolid.

Death of Socorro A. Ramos: Socorro A. Ramos died on November 10, 1965, without disclosing the foreclosure to the plaintiffs. Upon discovering the foreclosure, the plaintiffs demanded compensation or substitution of the land from Socorro's heirs, but their demands were refused.

Execution Sale of 18 Parcels: Pursuant to a court decision, the Ex-Oficio Sheriff of Quezon City levied and sold 18 parcels of land belonging to Socorro A. Ramos to the plaintiffs (Guillermo N. Pablo and Primitiva C. Cruz) for a lump sum of P56,885.22. The sale was confirmed, and new titles were issued in the names of the plaintiffs.

Heirs' Action for Annulment: The heirs of Socorro A. Ramos filed an action to annul the execution sale, alleging violations of procedural rules, lack of notice, and inadequacy of the sale price. They argued that the sale should have been conducted in parcels to maximize proceeds.

Res Judicata: Whether the principle of res judicata applies to bar the heirs' action for annulment of the execution sale.
Proper Remedy: Whether the heirs' remedy should have been a motion in the court of origin rather than a separate action.
Inadequacy of Price: Whether the inadequacy of the sale price was raised and whether it could invalidate the auction sale.
Moot and Academic: Whether the case is moot and academic due to the finality of the Supreme Court decision in G.R. No. L-23616.