Case Digest (G.R. No. 235725) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 29, 1958, Original Certificate of Title No. O-381 was issued in favor of Rafael Galvez over four parcels of land in Barrio Poro, San Fernando, La Union. In April 1960, Galvez sold Lots 1 (6,571 m²) and 4 (508 m²) to Filipina Mamaril, Cleopatra Llana, Regina Bustos, and Erlinda Balatbat, leading to TCT No. T-4304 in their names. In August 1960, they conveyed Lots 1 and 4 to Lepanto Consolidated Mining Company, which received TCT No. T-4314. Unknown to Lepanto, on February 1, 1963, the Court of First Instance, in Land Registration Case No. N-361, declared OCT No. O-381 null and void and ordered cancellation of subsequent titles. Lepanto sold the same lots to Shipside Incorporated on October 28, 1963, which obtained TCT No. T-5710 and exercised ownership since. All appeals by Galvez were resolved against him by 1973, and a writ of execution issued in 1974. In 1999 the Solicitor General filed a complaint for revival of judgment and cancellation of titles in Regional Trial Case Digest (G.R. No. 235725) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Shipside Incorporated (petitioner) seeks certiorari under Rule 65 against CA resolutions dated November 4, 1999 and May 23, 2000, which dismissed its petition for certiorari/prohibition and motion for reconsideration.
- Respondents: Court of Appeals (Special Former Twelfth Division), RTC Branch 26 (San Fernando City, La Union), and the Republic of the Philippines.
- Land Titles and Predecessor Transactions
- October 29, 1958: OCT No. 0-381 issued to Rafael Galvez for four parcels (Lots 1–4) in San Fernando, La Union.
- April 11, 1960: Galvez sold Lots 1 and 4 to Filipina Mamaril et al.; TCT No. T-4304 issued.
- August 16, 1960: Purchasers sold Lots 1 and 4 to Lepanto Consolidated Mining Co.; TCT No. T-4314 issued.
- October 28, 1963: Lepanto sold Lots 1 and 4 to Shipside; TCT No. T-5710 issued; Shipside exercised ownership.
- Cancellation Order and Non-Execution
- February 1, 1963: In LRC Case No. N-361, CFI La Union declared OCT No. 0-381 null and void; directed cancellation of OCT and subsequent titles.
- January 25, 1965: CFI denied Galvez’s motion for reconsideration; August 14, 1973: CA affirmed; writ of execution issued April 22, 1974 but never implemented.
- Revival Proceedings (Civil Case No. 6346)
- April 21, 1999: OSG filed for revival of judgment and cancellation of Torrens titles in RTC Branch 26; impleaded Shipside and other successors-in-interest.
- Shipside’s Motion to Dismiss (July 22, 1999) for: lack of cause of action (non-final judgment), non-real party, prescription, and 10-year limit for revival (Art. 1144(3), NCC).
- RTC denied MTD (Aug 31, 1999) and MRC (Oct 14, 1999). Shipside filed CA petition (Oct 21, 1999), dismissed (Nov 4, 1999) for lack of proof of signatory’s authority; MRC denied (May 23, 2000).
Issues:
- Corporate Authorization
- Whether Lorenzo Balbin, as resident manager, needed express Board authorization to sign the CA petition’s verification and certification against forum-shopping.
- Real Party and Prescription
- Whether the Republic may pursue revival of judgment and invoke imprescriptibility after RC 7227 transferred Camp Wallace to BCDA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)