Case Digest (G.R. No. L-10951)
Facts:
The case involves Spouses Julita de la Cruz and Felipe de la Cruz as petitioners, and Pedro Joaquin as the respondent. The litigation began when Pedro Joaquin filed a complaint for the recovery of possession and ownership of a parcel of land, cancellation of title, and damages against the spouses de la Cruz in the Regional Trial Court (RTC) of Baloc, Sto. Domingo, Nueva Ecija. On June 29, 1974, Pedro Joaquin allegedly obtained a loan of P9,000 from the petitioners, secured by a deed of sale covering land in Pinagpanaan, Talavera, Nueva Ecija, identified as TCT No. T-111802. The parties also executed a document called the "Kasunduan," which purportedly showed that the sale was actually a sale with a right of repurchase or an equitable mortgage.
The parties disputed the nature of their agreement, with the respondent asserting it was an equitable mortgage, while the petitioners contended it was a sale with a repurchase right that was not exercised within the five-year p
Case Digest (G.R. No. L-10951)
Facts:
- Background of the Case
- Pedro Joaquin (respondent) filed a Complaint for recovery of possession and ownership, cancellation of title, and damages against Spouses Julita and Felipe De La Cruz (petitioners) in the Regional Trial Court (RTC) of Baloc, Sto. Domingo, Nueva Ecija.
- Joaquin alleged that on June 29, 1974, he obtained a loan of P9,000 from petitioners, payable after five years (June 29, 1979). To secure payment, he executed a Deed of Sale over a parcel of land covered by TCT No. T-111802 in Pinagpanaan, Talavera, Nueva Ecija, in favor of petitioners.
- The parties also executed a "Kasunduan" (Agreement), which according to Joaquin, disclosed that the Deed of Sale was actually an equitable mortgage.
- Petitioners maintained that the Kasunduan merely accommodated the right of repurchase, which Joaquin failed to exercise by June 29, 1979.
- Proceedings Below
- On April 23, 1990, the RTC rendered a Decision declaring the transaction as a sale with right of repurchase. It held that Joaquin had validly tendered payment twice to repurchase the land.
- The trial court ordered petitioners to:
- Accept payment of P9,000 for repurchase;
- Execute a deed of reconveyance;
- Yield possession of the land to Joaquin; and
- Pay Joaquin P10,000 as actual and compensatory damages, P5,000 as exemplary damages, P5,000 for litigation expenses, and P5,000 as attorney's fees.
- The Court of Appeals (CA), in CA-GR CV No. 34702, affirmed the RTC's Decision on August 26, 2003, and denied a motion for reconsideration on March 9, 2004.
- The CA ordered substitution by legal representatives due to Joaquin’s death on December 24, 1988.
- Petitioners then filed a Petition for Review under Rule 45 of the Rules of Court before the Supreme Court.
Issues:
- Whether the trial court lost jurisdiction due to the death of Pedro Joaquin without substitution by heirs during the pendency of the case.
- Whether respondent (Joaquin) was guilty of forum shopping, warranting dismissal of the Complaint.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)