Title
Ruiz vs. J. M. Tuason and Co., Inc.
Case
G.R. No. L-18692
Decision Date
Jan 31, 1963
Florencio Deudor sold land to Jose Dinglasan, who transferred rights to Manuel B. Ruiz. Ruiz sued J.M. Tuason & Co. for specific performance, but the Supreme Court dismissed the case, ruling it a local action requiring venue in Quezon City, where the property is located.

Case Digest (G.R. No. L-18692)
Expanded Legal Reasoning Model

Facts:

  • Parties and Relief Sought
    • Plaintiff and Appellant: Manuel B. Ruiz.
    • Defendants and Appellees:
      • J. M. Tuason & Co., Inc.
      • Sheriff of Quezon City (implicated in the enforcement action).
    • Relief Sought by Plaintiff:
      • An injunction to prevent the execution of a writ of execution (issued in Civil Case No. Q-3492) which would evict him and demolish his house.
      • Specific performance compelling J. M. Tuason & Co., Inc. to execute a final deed of sale in his favor for a 420 sq. m. parcel of land at P7.00 per sq. m., recognizing P855.00 already paid as partial payment.
  • Background of the Property Transaction
    • Original Ownership and Sale:
      • Defendant Florencio Deudor was the absolute owner and possessor of 210,000 square meters of land in Barrio Tatalon, Quezon City.
      • The land was covered by a possessory information title in the name of his deceased father, Telesforo Deudor.
    • Conveyance to Third Parties:
      • Florencio Deudor sold a portion of this land for an absolute sale consideration of P4,800.00.
      • The property sold was described as Lot No. 72 of a subdivision plan in Barrio Tatalon, bounded by adjoining lots and streets.
    • Possession and Partial Improvements:
      • Jose Dinglasan, one of the vendees, took possession of a 420 sq. m. portion of the sold lot.
      • Jose Dinglasan erected two houses of strong materials on the said parcel, which were declared for taxation purposes.
  • Development of the Dispute and Prior Litigation
    • Payment Issues and Pending Litigation:
      • In 1950, Jose Dinglasan attempted to pay the balance of the purchase price, but Florencio Deudor refused due to a pending action (Civil Case No. Q-135) involving conflicting claims on the land.
    • The Compromise Agreement:
      • In Civil Case No. Q-135 along with related cases (Nos. Q-139, 174, 177, and 186), the parties entered into a Compromise Agreement on March 16, 1953.
      • Paragraph 7 of the agreement dealt with:
        • Recognition of the sales by the Deudors as reflected in lists attached as Annexes “B” and “C”.
        • Crediting and refunding of amounts paid by buyers (including a record of P865.00 paid by Jose Dinglasan) against the total sum due.
    • Subsequent Conveyances Leading to Plaintiff’s Possession:
      • Jose Dinglasan transferred his rights over the 420 sq. m. parcel to spouses Sixto M. Cacho and Julita de Jesus.
      • The spouses then transferred all rights and interests to the plaintiff, Manuel B. Ruiz, who subsequently took possession of the property and its improvements.
  • The Writ of Execution and Venue Conflict
    • Nature of the Writ and Its Enforcement:
      • J. M. Tuason & Co., Inc. obtained a default judgment against Sixto M. Cacho in Civil Case No. Q-3492 (filed on November 20, 1958) in the Court of First Instance of Rizal, Quezon City Branch IV.
      • A writ of execution was subsequently obtained and issued on May 20, 1959, which empowered the Sheriff of Quezon City to enforce it—threatening to eject the plaintiff and demolish his residence.
    • Procedural Motions and Dismissal for Venue:
      • Defendant Florencio Deudor filed a motion to dismiss on three grounds:
        • Improper venue.
        • Lack of cause of action against him.
        • Prescription of the cause of action, if any existed.
      • Defendant J. M. Tuason & Co., Inc. countered with a motion for a bill of particulars.
      • Despite the pending opposition and motion for bill of particulars, the trial court (Court of First Instance of Manila) dismissed the case on March 11, 1961, solely on the ground that the venue was improvidently chosen given that the subject property is situated in Quezon City.
  • Plaintiff’s Argument on the Nature of the Action
    • Plaintiff contended that the present action was transitory and one for specific performance.
    • He argued that the relief sought – a final deed of sale – was ancillary to his payment and should not render the action a matter of ownership dispute.
    • The primary issue, however, centered around the proper determination of ownership – an issue that necessarily required adjudication in the province where the property is located.

Issues:

  • Venue Appropriateness
    • Is the Court of First Instance of Manila the proper forum when the subject property is located in Quezon City?
    • Does the involvement of an injunction (an ancillary relief) change the nature of the case regarding venue determination?
  • Nature and Substance of the Relief Sought
    • Does the plaintiff’s claim for specific performance (execution of a final deed of sale) constitute a transitory or purely contractual remedy?
    • To what extent does the effectively ownership-determination nature of the relief require the action to be filed in the locale where the land is situated?
  • Effect of the Writ of Execution
    • How does the pending execution of the writ of execution affect the plaintiff’s rights and the determination of title and possession of the subject property?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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