Case Digest (G.R. No. 94918) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Suarez v. Court of Appeals (G.R. No. 94918, September 2, 1992), petitioners Danilo I. Suarez, Eufrocina Suarez-Andres, Marcelo I. Suarez, Jr., Evelyn Suarez-De León and Reginio I. Suarez are the legitimate children of the late Marcelo Suarez, who died in 1955 without liquidating or partitioning his estate consisting of five valuable parcels of land in Pasig, Metro Manila. In 1977, their surviving mother, Teofista Suarez, and Rizal Realty Corporation were sued in consolidated actions before the Court of First Instance of Rizal (now RTC, Pasig) for rescission and damages and were ordered to pay approximately ₱70,000.00. Execution was levied en masse on June 24, 1983, on all five parcels registered in the name of the deceased father, and respondents Valente Raymundo, Violeta Raymundo, Ma. Concepcion Vito and Virginia Banta became the highest bidders at ₱94,170.00. A certificate of sale was registered on August 1, 1983, and a final deed of sale was issued on July 31, 1984. On Jun Case Digest (G.R. No. 94918) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Danilo I. Suarez, Eufrocina Suarez-Andres, Marcelo I. Suarez, Jr., Evelyn Suarez-De Leon and Reginio I. Suarez—five siblings and co-owners of five parcels of land in Pasig, Metro Manila, registered in the name of their deceased father, Marcelo Suarez.
- Private Respondents: Valente Raymundo, Violeta Raymundo, Ma. Concepcion Vito and Virginia Banta—highest bidders in the public auction sale of the five parcels.
- Procedural History
- 1977 Judgment: Teofista Suarez (widow of Marcelo Suarez) and Rizal Realty Corporation were ordered by CFI Rizal (now RTC Pasig, Branch 151) to pay respondents approx. ₱70,000 as damages for rescission of contract.
- Execution Sale (June 24, 1983): All five parcels were levied en masse and sold for ₱94,170; Certificate of Sale issued Aug 1, 1983.
- Reinvidicatory Action (June 21, 1984): Petitioners filed Civil Case No. 51203 to annul the sale, claiming they were co-owners not liable for their mother’s debt.
- Subsequent Orders and Motions (1984–1990):
- RTC Branch 151 issued orders directing surrender of titles and vacatur of lots (Oct 10, 1984).
- Writ of Preliminary Injunction granted (Feb 25, 1985) enjoining respondents from transferring the properties.
- Multiple motions to dismiss for failure to prosecute; divergent rulings by Branch 155 (dismissal May 29, 1986; reinstatement June 10, 1987).
- Court of Appeals rendered certiorari decision (July 27, 1990) annulling injunction orders and dismissing Civil Case No. 51203.
Issues:
- Principal Issues
- Whether private respondents can validly acquire the entire five co-owned parcels in an execution sale to satisfy the personal debt of the surviving spouse.
- Whether an execution sale may extend beyond the debtor’s proprietary interest in co-owned property.
- Secondary Issues
- Whether petitioners, as co-owners and non‐parties to the original judgment, have standing to annul the auction sale.
- Whether Article 777, 888 and 892 of the Civil Code limit the levy to the debtor’s disposable share only.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)