Case Digest (G.R. No. 179594)
Facts:
In G.R. No. 217148, decided on December 7, 2021 under the 1987 Constitution, Rapid City Realty and Development Corporation (Petitioner), together with Sta. Lucia Realty and Development, Inc., filed a complaint before the Regional Trial Court (RTC) of Antipolo City, Branch 71, for annulment of subdivision and consolidation plans, cancellation of multiple Transfer Certificates of Title (TCT) covering Lot 2 (LRC) Psd-214777 in Barangay San Isidro, Antipolo City, reformation of a Deed of Absolute Sale dated February 26, 2003, quieting of titles, declaratory relief, mandamus and damages against respondents Lourdes Estudillo Paez-Cline alias Lourdes Paez-Avilla and Orlando Villa (Spouses Villa), the Department of Public Works and Highways (DPWH), the Department of Environment and Natural Resources (DENR), the Register of Deeds of Antipolo City and the Office of the Solicitor General (OSG). The petitioners alleged that Lot 2 formed part of the Marikina-Infanta Road (now Marcos Highway)Case Digest (G.R. No. 179594)
Facts:
- Parties and Subject Matter
- Petitioners Sta. Lucia Realty and Rapid City Realty (developers of Parkehills Executive Village) filed a complaint against spouses Lourdes Paez-Cline alias Avilla and Orlando Villa (Spouses Villa), Department of Public Works and Highways (DPWH), Department of Environment and Natural Resources (DENR), Register of Deeds of Antipolo, and Office of the Solicitor General (OSG).
- They sought:
- Nullification of subdivision plans (Psd-04-118781; Pcs-04-015503) covering Lot 2 (LRC) Psd-214777 (21,437 sq. m.) in Antipolo City.
- Cancellation of TCT Nos. 409502–409504 and derivative titles.
- Nullification or reformation of the Deed of Absolute Sale (Feb. 26, 2003) by which Lourdes sold Lot 2 to the Republic through DPWH.
- Specific performance, quieting of titles, damages, declaratory relief, mandamus.
- Trial Court Proceedings
- Summons served in September 2004; Spouses Villa, DPWH, DENR, Register of Deeds, and OSG failed to timely answer and were declared in default.
- Plaintiffs presented ex-parte evidence (testimony of Rapid City’s president and a DENR survey chief; exhibits A–QQ).
- RTC Decision (Sept. 4, 2007) annulled the plans, titles, and sale deed; reformed title in favor of the Republic; quieted titles of lot owners; awarded damages and attorney’s fees.
- Appellate History
- Spouses Villa, OSG, and DPWH appealed to the Court of Appeals (CA).
- CA Decision (July 1, 2014) reversed and set aside the RTC ruling, dismissed the complaint for lack of real party in interest and cause of action; denied petitioner’s motion for reconsideration (Feb. 23, 2015).
- Rapid City Realty filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether the CA erred in declaring that petitioner is not a real party in interest and that the complaint states no cause of action against respondents.
- Whether the CA erred in not affirming the RTC Decision.
- Whether the CA misappreciated or misapprehended the facts, amounting to grave abuse of discretion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)