Case Digest (G.R. No. L-12084)
Facts:
In the case of Pedro Samson et al. vs. Hon. Nicasio Yatco, et al., which was decided by the Supreme Court of the Philippines on August 25, 1958, the petitioners were Pedro Samson, Florencia Cruz Vda. de Guzman, and Maria Santos. They were the occupants of Lot No. 10, Block No. 45 of the Grace Park Subdivision located in Caloocan, Rizal. The lot, which had a total area of approximately 650 square meters, was owned by the Philippine Realty Corporation. Samson claimed the northern portion (162.50 square meters), while Cruz Vda. de Guzman and Santos occupied the remaining part. On March 21, 1951, Cruz and Santos purchased the property on an installment basis from the corporation. Subsequently, Samson alleged that he had entered into an agreement with Cruz and Santos to pay part of the down payment and make the regular monthly payments for the portion he occupied. However, the evidence indicated that Samson failed to fulfill his part, as the other two petitioners continued to pay th
Case Digest (G.R. No. L-12084)
Facts:
- Parties and Property
- Petitioners:
- Pedro Samson, who occupied approximately 162.50 square meters of Lot No. 10, Block No. 45 of the Grace Park Subdivision in Caloocan, Rizal.
- Mariano Reyes, son-in-law of Samson, later involved as a successor-in-interest.
- Respondents:
- Florencia Cruz Vda. de Guzman and Maria Santos, who occupied the remaining part (about 487.50 square meters) of the lot.
- The Philippine Realty Corporation, original owner of the lot.
- Other respondents including the Register of Deeds of Rizal and the Sheriff of Quezon City.
- Property Details:
- The subject property is Lot No. 10, Block No. 45 within a subdivision built by the Philippine Realty Corporation.
- The lot was divided in terms of physical occupation between petitioner and respondents.
- Transaction History and Partition Agreement
- On March 21, 1951, Florencia de Guzman and Maria Santos purchased the lot on an installment basis from the Philippine Realty Corporation.
- An alleged separate agreement between Pedro Samson and the vendees stipulated that Samson would pay part of the down payment and monthly installments for the portion he occupied.
- It appears that Samson did not fulfill his payment obligation as De Guzman and Santos paid all installments for the entire lot until its final payment on December 3, 1954.
- A partition agreement was purportedly executed on June 15, 1951, which assigned the northern portion to Samson and the remainder to the other buyers, although controversy arose regarding the approval and execution of said document.
- Amicable Settlement and Subsequent Obligations
- On December 15, 1955, the parties reached an "Amicable Settlement":
- The property was divided with Samson receiving a one-fourth (1/4) portion corresponding to the area he occupied.
- The remainder of the lot was allotted to De Guzman and Santos.
- Obligations on Samson under the settlement:
- He was required to pay for the segregation (subdivision) of his share.
- He was to reimburse the defendants for the purchase price of the said one-fourth portion (net of his initial down payment) at a stipulated interest rate.
- A critical condition (paragraph 10) mandated that Samson commence the segregation within three months after receiving a copy of the decision; failure to do so would result in the automatic loss of his rights over his share and required a refund of all payments made.
- Subsequent Transactions and Lower Court Proceedings
- On January 7, 1956, Samson sold and conveyed his right over the 1/4 portion to his son-in-law, Mariano Reyes, for P2,600.
- On January 17, 1956, Samson paid De Guzman and Santos the purchase price plus interest amounting to P1,418.30.
- Defendants later moved to cancel Samson’s right:
- On May 8, 1956, De Guzman and Santos filed a motion arguing that Samson had failed to comply with the segregation condition.
- On May 12, 1956, due to Samson’s non-appearance at the hearing, the Court ordered the cancellation of his rights over the one-fourth portion and directed that any funds received from him be refunded.
- Samson filed a series of motions for reconsideration:
- On February 6, 1957, he sought reconsideration of the cancellation order as well as the eviction order (January 19, 1957) requiring him to vacate the premises.
- The Court denied these motions, stating that they were filed long after the orders had attained finality.
- Petition for Certiorari:
- In view of the lower court’s orders becoming final and executory, Samson (and his son-in-law, Mariano Reyes, though the latter was not a proper party in the earlier proceedings) filed a petition for certiorari.
- A writ of preliminary injunction was issued upon bond by the petitioners.
Issues:
- Timeliness and Procedural Validity
- Whether the lower Court committed grave abuse of discretion in denying Samson’s motion for reconsideration which was filed long after the orders (cancellation of rights, issuance of title in defendant’s names, and order to vacate) had become final and executory.
- Enforcement of the Amicable Settlement and Lower Court Orders
- Whether the cancellation of Samson’s rights over the one-fourth portion and the subsequent order for him to vacate the property were proper implementations of the amicable settlement conditions.
- Binding Effect of Lower Court Orders on Successors-in-Interest
- Whether the final and executory orders bind only petitioner Pedro Samson or extend to his assignee, Mariano Reyes, who acquired an interest in the disputed property.
- Jurisdictional Considerations
- Whether the Court of First Instance had jurisdiction to order Samson’s eviction in a matter that was not strictly an action for ejectment, particularly given the nature of the partition and installment dispute.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)