G.R. No. 237812 - Spouses Rebamonte vs. Spouses Lucero

The subject property involves two portions of land, each one hectare, which are parts of a larger lot known as Lot No. 1305-A.
Lot No. 1305-A has an area of 47,817 square meters, located at Mamali II, Lambayong, Province of Cotabato (now Sultan Kudarat), and is covered by Transfer Certificate of Title (TCT) No. T-17712 in the name of respondent Guillermo Lucero.
The property’s history includes a previous title (TCT No. T-26792) registered in the name of respondent Guillermo’s parents, Marcos Lucero and Tomasa Rebamonte, who originally owned the lot.

On June 30, 1970, Marcos and Tomasa obtained a loan from the Rehabilitation Finance Corporation (now the Development Bank of the Philippines), using Lot No. 1305-A as collateral.
For nonpayment of the loan, DBP foreclosed the lot via extrajudicial foreclosure and later purchased it at auction.
Before the cancellation of TCT No. T-26792 and issuance of a new title in DBP’s name, DBP entered into a repurchase agreement with Marcos and Tomasa, allowing them to regain ownership.
Subsequently, on November 14, 1980, Marcos and Tomasa sold Lot No. 1305-A to respondent Guillermo through a Deed of Absolute Sale, leading to the cancellation of the old title and issuance of TCT No. T-17712 in Guillermo’s name.

Prior to the sale on November 14, 1980, three separate unregistered sales allegedly occurred:

On February 5, 1976, Tomasa sold a one-hectare portion of Lot No. 1305-A to petitioner Lino (evidenced by a private receipt).
On May 29, 1976, Josefina Lucero-Oprecio, respondent Guillermo’s sister, executed a Deed of Absolute Sale conveying another one-hectare portion to petitioner Lino.
On June 17, 1980, Agripina Lucero-Reyes, another sister of respondent Guillermo, executed a Deed of Absolute Sale conveying a further one-hectare portion to petitioner Lino.

As petitioner Lino took possession of these portions, respondent Guillermo was deprived of full possession of the lot, prompting repeated demands for eviction which petitioner Lino refused.

To recover possession and quiet title over the portions occupied by petitioner Lino, respondents Guillermo and Genoveva Lucero filed a Complaint for Recovery of Real Estate Property, Recovery of Possession, Quieting of Title, Damages, and Attorney’s Fees before the Regional Trial Court (RTC) of Tacurong City, Branch 20 (Civil Case No. 241).
The petitioners (Sps. Rebamonte), representing petitioner Lino and his compulsory heirs, filed an Answer on April 24, 1990, followed by an Amended Answer; respondents later filed an Amended Complaint and a Reply/Answer to Counterclaim, contesting the validity of the Deeds of Absolute Sale executed by Josefina and Agripina.
Petitioners argued that there was an advance inheritance agreement whereby Tomasa had already granted rights over the two one-hectare portions to respondent Guillermo’s sisters as their advance inheritance.

On February 3, 2012, the RTC rendered a Judgment voiding the two Deeds of Absolute Sale (May 29, 1976 and June 17, 1980), holding that Josefina and Agripina had no right to convey any portion of the lot since the true owners were Marcos and Tomasa, who had never authorized any such sale.
The RTC, however, upheld the validity of the one-hectare sale made on February 5, 1976 by Tomasa to petitioner Lino, ordering the Registrar of Deeds to annotate the sale and directing petitioner Lino and his successors to vacate the two voided portions.
The petitioners later filed a Motion for Reconsideration (denied on November 3, 2015) and appealed the RTC decision to the Court of Appeals (CA), where the relief was denied and the RTC decision was affirmed in toto.
Petitioners then raised their appeal issues on multiple grounds—including jurisdictional error, defective service of summons, and failure to substitute respondent Guillermo upon his death—after decades of active and participative litigation.

Whether the RTC had jurisdiction over the Complaint, given that the assessed value of the subject property portions falls within the competence of the Municipal Trial Court (MTC) rather than the RTC.
Whether the fact that the assessed value of the subject portions (2 hectares) is below the statutory threshold (Php 20,000.00) renders the RTC’s involvement improper.

Whether there was defective service of summons due to the use of substituted service that did not comply with formal requirements and whether this defective service nullified the proceedings against petitioner Teresita Rebamonte.

Whether the failure to effect substitution for respondent Guillermo after his death (in September 2000) violated Rule 3, Section 16 of the Rules of Court, and if such failure renders the RTC’s decision null and void.

Whether there exists any reversible error in the factual findings of the RTC and subsequently the CA regarding the nullity of the Deeds of Absolute Sale executed by respondent Guillermo’s sisters.