G.R. No. 144294 - Ramos vs. Ramos

Petitioners are the children of the late Paulino V. Chanliongco Jr., a co-owner of a parcel of land.
The land in issue is designated as Lot No. 2-G of Subdivision Plan SWO No. 7308, located in Tondo, Manila.
Respondents include Teresita D. Ramos, spouses Teresita and Edmundo S. Muyot, spouses Vedasta and Florencio M. Dato, Loreto Muyot, spouses Teresita and Elmer Solis, Liceria Torres, spouses Corazon and Vicente Macatungal, spouses Precilla and Crisostomo Muyot, and spouses Caridad and Salvador Pingol.

A Special Power of Attorney was executed in favor of Narcisa (a co-owner) which authorized her daughter, Adoracion C. Mendoza, to sell her mother’s share of the property.
On different days in September 1986, Adoracion C. Mendoza sold the lot to the respondents.
Conflict arose among the heirs regarding the validity of the sale due to questions about the authority conferred by the Special Power of Attorney, as the document was executed solely in favor of Narcisa.

Respondents initiated litigation by filing a Complaint for interpleader in the Regional Trial Court (RTC) to resolve the dispute over the various ownership claims.
The RTC ruled in favor of respondents insofar as it upheld the sale of Narcisa’s share and held that Adoracion lacked authority to dispose of the interests of the other co-owners.
On appeal, the Court of Appeals (CA) modified the RTC ruling.

The CA held that despite the absence of an express Special Power of Attorney in favor of Adoracion, she acted as a sub-agent authorized by her mother.
Consequently, there was no requirement to execute a distinct special power of attorney designating her as such.

The CA Decision, rendered on September 28, 1995, was not appealed and became final and executory by August 8, 1996.

On April 10, 1999, petitioners filed a Motion to Set Aside the CA Decision before the CA alleging a due process violation.

They contended that they were not served a copy of the Complaint or the summons.
Additionally, petitioners were not impleaded as parties in the RTC proceedings.
They argued that the CA Decision adversely affected their shares in the property without affording them due process.

Petitioners subsequently elevated the case to the Supreme Court via a Petition for Review under Rule 45 of the Rules of Court.
The central claim involved whether the CA erred in denying the motion in light of the alleged failure to serve petitioners and thus violating due process.

Whether the CA erred in denying petitioners’ Motion by allowing the CA Decision to take effect despite the alleged failure to serve petitioners with summons.
Whether the lack of service, as petitioners were not included as parties in the RTC action, amounted to a violation of due process.

Whether the action, being a real action aimed at determining title and ownership of the property, required the implementation of service of summons upon petitioners, who subsequently held an inchoate interest as heirs.
Whether the representation of petitioners' interest by the estate of the deceased and their duly appointed counsel was sufficient to satisfy the due process requirements applicable to the service of summons.