Case Digest (G.R. No. 143377)
Facts:
- The case involves Shipside Incorporated (petitioner) and the Court of Appeals, Regional Trial Court (Branch 26, San Fernando City, La Union), and the Republic of the Philippines (respondents).
- The dispute is over Lots No. 1 and 4, originally covered by Original Certificate of Title (OCT) No. 0-381 in the name of Rafael Galvez.
- These lots were sold to Filipina Mamaril, Cleopatra Llana, Regina Bustos, and Erlinda Balatbat, who then sold them to Lepanto Consolidated Mining Company on August 16, 1960.
- Lepanto conveyed the property to Shipside Incorporated on October 28, 1963, resulting in the issuance of Transfer Certificate of Title (TCT) No. T-5710.
- Unknown to Lepanto, OCT No. 0-381 had been declared null and void by the Court of First Instance (CFI) of La Union on February 1, 1963, a decision that became final and executory on October 23, 1973.
- On April 21, 1999, the Office of the Solicitor General filed a complaint for revival of judgment and cancellation of titles.
- Shipside moved to dismiss, arguing that the Republic was not the real party-in-interest and that the action was barred by prescription.
- The trial court denied the motion, and the Court of Appeals upheld this decision.
- Shipside petitioned the Supreme Court, which granted the petition, ruling that the action was barred by extinctive prescription and that the Republic was not the real party-in-interest.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the action for revival of judgment was barred by extinctive prescription.
- The Supreme Court ruled that the Republ...(Unlock)
Ratio:
Prescription:
- An action for revival of judgment must be brought within ten years from the time the judgment becomes final, as stipulated in Article 1144(3) of the Civil Code and Section 6, Rule 39 of the 1997 Rules on Civil Procedure.
- In this case, the judgment became final on October 23, 1973, but the action for revival was instituted only in 1999, more than twenty-five years later.
- Therefore, the action was barred by extinctive prescription.
Real Party-in-Interest:
- While prescription does not run against the State, this principle could not be invoked by the government in this case because it no longer had an interest in the subject matter.
- The land in ...continue reading
Case Digest (G.R. No. 143377)
Facts:
The case involves Shipside Incorporated (petitioner) and the Court of Appeals, Regional Trial Court (Branch 26, San Fernando City, La Union), and the Republic of the Philippines (respondents). The dispute centers on Lots No. 1 and 4, originally covered by Original Certificate of Title (OCT) No. 0-381 in the name of Rafael Galvez. These lots were sold to Filipina Mamaril, Cleopatra Llana, Regina Bustos, and Erlinda Balatbat, who then sold them to Lepanto Consolidated Mining Company on August 16, 1960. Lepanto subsequently conveyed the property to Shipside Incorporated on October 28, 1963, resulting in the issuance of Transfer Certificate of Title (TCT) No. T-5710. Unknown to Lepanto, OCT No. 0-381 had been declared null and void by the Court of First Instance (CFI) of La Union on February 1, 1963, a decision that became final and executory on October 23, 1973. On April 21, 1999, the Office of the Solicitor General filed a complaint for revival of judgment and cancellation of titles, which Shipside moved to dismiss, arguing that the Republic was not the real party-in-interest and that the action was barred by prescription. The trial court denied the motion, and the Court of Appeals upheld this decision. Shipside then petitioned the Supreme Court, which granted the petition, ruling t...