G.R. No. L-37168-69 - People vs. Beltran

Petitioner Sigma Homebuilding Corporation filed a complaint for annulment of sale, cancellation of titles, reconveyance, and damages against several respondents.
The respondents include Inter-Alia Management Corporation, Development Bank of Rizal (DBR), Intercon Fund Resources Corporation, Hasting Realty and Development Corporation, and the Register of Deeds for the Province of Cavite.
The subject matter involves real properties in Tanza, Cavite, with an approximate total area of 126,910 sq. m.

Petitioner alleged that its assistant vice-president, Augusto S. Parcero, sold the properties to Inter-Alia without the knowledge or consent of the corporation, and without the necessary board resolution authorizing the transaction.
It was further contended that Inter-Alia, having acquired the properties, subsequently sold them to DBR.
DBR then sold the properties to Intercon, which in turn conveyed them to Hasting Realty and Development Corporation.

Summonses were served on all respondents except Inter-Alia, due to the latter no longer holding office at its listed address.
Hasting Realty and Development Corporation filed a motion to dismiss on the ground that the complaint did not state a cause of action, citing:

Annotations in the petitioner’s cancelled transfer certificates of title (TCTs) which implied that Parcero was authorized to execute the sale.
The presence of a duly notarized deed of absolute sale and an acknowledged receipt evidencing the total consideration amounting to P1,522,920.00.

Hasting also argued that, by the complaint’s own presentation, petitioner might not even be a real party in interest concerning the subsequent transfers of the properties.
The Regional Trial Court (RTC) of Trece Martires City, Branch 23, dismissed the complaint for failure to state a cause of action and ruled that the action for reconveyance was improper because the properties had passed to innocent purchasers in good faith and for value.

Petitioner moved for reconsideration before the RTC, which was denied.
An appeal was then filed with the Court of Appeals (CA) and the CA affirmed the RTC’s dismissal.
Petitioner also filed a petition for reconsideration with the CA, which was likewise denied.
A subsequent petition for review on certiorari was filed before the Supreme Court, but it was denied for failure to show that the appellate court committed any reversible error.
Petitioner then attempted to annul the RTC order (dated July 3, 2002) by filing a petition in the CA alleging lack of jurisdiction under Rule 47, arguing that the trial court exceeded its powers by dismissing the complaint against respondents who did not move for dismissal.
The CA denied the petition for annulment, emphasizing that:

For an action for annulment of judgment based on lack of jurisdiction to succeed, it must be shown that the court absolutely lacked jurisdiction or should not have taken cognizance of the case.
Petitioner had exhausted its remedy through ordinary appeal before both the CA and the Supreme Court.

A letter-appeal was later filed by petitioner on June 30, 2008, in an apparent attempt to invoke a second motion for reconsideration, which is prohibited under the Rules of Court, especially after judgment had already become final and executory.
The Supreme Court ultimately denied the letter-appeal, characterizing it as a ruse aimed to evade the finality of the decision, and imposed treble costs against petitioner.

Whether the RTC and subsequently the CA erred in dismissing the complaint for failure to state a cause of action, particularly with respect to the inclusion of multiple respondents not deemed real parties in interest.
Whether the petitioner was deprived of its right to due process by the dismissal against respondents other than Hasting Realty and Development Corporation, which was asserted as the only real party in interest.

Whether petitioner’s subsequent petition for annulment of the RTC order, on grounds of lack of jurisdiction, could be entertained given that it had already availed of an ordinary appeal.
Whether a letter-appeal, effectively a second motion for reconsideration filed after the judgment became final, is procedurally permissible.

Whether the annotations in the cancelled TCTs, the notarized deed of absolute sale, and the receipt of consideration effectively establish that the sale was properly and validly executed with proper authority.