Case Digest (G.R. No. 166838)
Facts:
Sta. Lucia Realty & Development, Inc. v. City of Pasig, G.R. No. 166838, June 15, 2011, promulgated May 14, 2012, Supreme Court First Division, Leonardo‑De Castro, J., writing for the Court.The parties are Sta. Lucia Realty & Development, Inc. (petitioner and registered owner of several parcels), City of Pasig (respondent claiming entitlement to collect real property taxes), and the Municipality of Cainta, Province of Rizal (intervenor claiming territorial jurisdiction over the subject lots). Sta. Lucia held several Transfer Certificates of Title (TCT Nos. 39112, 39110 and 38457) that on their face indicated the lots were located in Barrio Tatlong Kawayan, Pasig (now City of Pasig). The parcel under TCT No. 39112 had been consolidated and later partitioned, producing new TCTs (532250, 598424, 599131) which bear a Cainta address; other original TCTs were likewise subdivided. A commercial building on TCT No. 38457 was owned by a related but separate corporation.
Procedurally, Cainta began a boundary‑dispute case against Pasig in the Antipolo Regional Trial Court (RTC), Branch 74, on January 31, 1994 (Civil Case No. 94‑3006), which remains pending. Pasig filed a complaint for collection of real estate taxes (including penalties and interest) against Sta. Lucia on November 28, 1995 in the RTC of Pasig, Branch 157 (Civil Case No. 65420). Sta. Lucia answered that it had been paying realty taxes to Cainta since 1913 and that Cainta had issued the relevant tax declarations; Cainta intervened, asserting continuous collection of taxes and that boundary monuments would show the lots lie within Cainta.
Sta. Lucia and Cainta moved to suspend the Pasig collection proceeding as presenting a "prejudicial question" pending resolution of the Antipolo RTC boundary case; the Pasig RTC denied the motion (Dec. 4, 1996). The Pasig RTC rendered judgment for Pasig on August 10, 1998 ordering Sta. Lucia to pay unpaid taxes and ordering Cainta to refund taxes it had collected. On Pasig's motion for reconsideration the RTC, by order dated October 9, 1998, modified the decision to include unpaid taxes on improvements (P5,627,757.07). Sta. Lucia and Cainta appealed to the Court of Appeals (CA) (CA‑G.R. CV No. 69603); Pasig sought execution pending appeal, and on April 15, 1999 the RTC ordered issuance of a writ of execution.
Sta. Lucia filed a Rule 65 certiorari petition with the CA (CA‑G.R. SP No. 52874) to assail the writ of execution; the CA First Division granted that petition on September 22, 2000, setting aside the RTC order and stating that the Antipolo RTC boundary dispute presented a prejudicial question. Pasig's attempt to overturn that CA ruling by certiorari to the Supreme Court was denied as tardy (petition filed Nov. 29, 2000; denied June 25, 2001). Meanwhile, the Seventh Division of the CA, in CA‑G.R. CV No. 69603, on June 30, 2004 affirmed the Pasig RTC judgment with modification (deleting awarded attorney's fees) and denied motions for reconsideration (Resolution Jan. 27, 2005). Sta. Lucia then filed the present petition for certiorari before the Supreme Court (G.R. No. 166838); Cainta filed a separate petition (G.R. No. 166856) which was denied by this Court on April 13, 2005.
Sta. Lucia's assignments of error chiefly argued that (1) the CA erred in affirming the Pasig RTC decision without suspending the case pending resolution of the territorial boundary dispute; (2) payments to Cainta constituted valid...(Subscriber-Only)
Issues:
- Did the Pasig RTC and the Court of Appeals err in deciding Pasig’s tax collection complaint without awaiting final resolution of the boundary dispute between Pasig and Cainta?
- Should Sta. Lucia be required to continue paying its real property taxes to Cainta, or to Pasig, pending the boundary...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)