Case Digest (G.R. No. 159786) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ricardo S. Silverio, Jr., Esses Development Corporation and Tri-Star Farms, Inc. v. Filipino Business Consultants, Inc. (G.R. No. 143312, August 12, 2005), Silverio, Jr. was president of Esses Development Corporation and Tri-Star Farms, Inc., registered owners of a 62-hectare parcel in Calatagan, Batangas (TCT No. T-55200). On September 22, 1995, Esses and Tri-Star executed a Deed of Sale with Assumption of Mortgage in favor of Filipino Business Consultants, Inc. (FBCI). After failing to redeem, FBCI filed a Petition for Consolidation of Title before the RTC Balayan (Civil Case No. 3356) on May 27, 1997. FBCI obtained a default judgment, leading to issuance of a writ of possession on April 20, 1998. Upon learning of the default judgment, Silverio, Jr., Esses and Tri-Star secured its nullification on December 28, 1998, for lack of jurisdiction due to fraudulent service of summons, and regained possession by virtue of a restitution order under Rule 39, § 5. While the consolidat Case Digest (G.R. No. 159786) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Dispute
- Parties and Property
- Petitioners: Ricardo S. Silverio, Jr. (President), Esses Development Corp. and Tri-Star Farms, Inc.
- Respondent: Filipino Business Consultants, Inc. (FBCI; now Filipino Vastland Co., Inc.)
- Subject: 62-hectare “Calatagan Property” in Batangas, Titular Certificates T-55200 (Esses/Tri-Star) and later T-77656 (FBCI)
- Deed of Sale and Default
- 22 September 1995 – Esses and Tri-Star sold property to FBCI with assumption of mortgage
- Failure to redeem led FBCI to file consolidation petition on 27 May 1997
- RTC Balayan Proceedings
- Default Judgment and Writ of Possession
- FBCI obtained default judgment; TCT in petitioners’ names canceled; new title issued to FBCI
- 20 April 1998 – writ of possession issued; FBCI took over the land
- Relief from Judgment and Restitution
- Petitioners moved to set aside default for fraudulent service; 28 December 1998 – RTC nullified judgment and writ
- Subsequent RTC orders (April–November 1999) restored possession to petitioners under Rule 39, §5
- Attempt to Enforce and Suspension of Writ
- 8 May 2000 – RTC issued writ of possession to petitioners; FBCI filed motions to recall/suspend execution
- 26 May 2000 – ex parte motion by FBCI claiming a supervening event (acquisition of controlling shares in Esses/Tri-Star); RTC Balayan suspended writ
- 15–17 June 2000 – RTC Balayan scheduled and then canceled hearings on supervening event to await higher-court action, but lifted suspension effective 17 June 2000
Issues:
- Procedural Questions
- Is an appeal under Rule 45 proper to assail an order suspending a writ of possession, or must one resort to certiorari (Rule 65)?
- Did the RTC Balayan’s 15 June 2000 Order render the controversy moot and academic?
- Does petitioners’ filing of a separate annulment-of-contract case in Las Piñas constitute forum shopping?
- Substantive Questions
- Did the RTC Balayan exceed its authority in suspending the writ of possession and holding hearings on a claimed supervening event?
- Did FBCI’s acquisition of controlling shares in Esses and Tri-Star qualify as a supervening event justifying suspension of the writ?
- Is the dispute over share acquisition an intra-corporate controversy beyond the RTC’s jurisdiction?
- Has res judicata or due process precluded the RTC from revisiting these issues?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)