Case Digest (G.R. No. 57268) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves Titan Dragon Properties Corporation (petitioner) and Marlina Veloso-Galenzoga (respondent) concerning a 70,364-square meter parcel of land in Barangay Damayan Lagi, New Manila, Quezon City, registered under TCT No. 185260 in the name of the petitioner. On December 8, 1997, the petitioner, through its president Antonio L. Yao, allegedly sold the property to respondent via a Deed of Absolute Sale for ₱60,000,000, obliging the petitioner to pay Capital Gains Tax (CGT) and Documentary Stamp Tax (DST) while the respondent would shoulder transfer tax and registration fees. Since 1997, respondent claimed to have paid real property taxes and requested that petitioner deliver possession and pay the requisite taxes, demands which allegedly remained unheeded until Yao’s death.
Respondent filed a complaint for specific performance on April 7, 2015 (Civil Case No. R-QZN-15-03231-CV, assigned to Branch 95-RTC), to compel the petitioner’s compliance with its obligations. Two
Case Digest (G.R. No. 57268) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioner: Titan Dragon Properties Corporation (petitioner corporation)
- Respondent: Marlina Veloso-Galenzoga (respondent)
- Subject property: A 70,364-square meter parcel of land located in Barangay Damayan Lagi, New Manila, Quezon City registered under TCT No. 185260 in petitioner’s name.
- Transaction Background
- Petitioner corporation, through its then-President Antonio L. Yao, allegedly sold the subject property to respondent by a Deed of Absolute Sale dated December 8, 1997, for Php60,000,000.00.
- The Deed obligated petitioner corporation to pay the capital gains tax (CGT) and documentary stamp tax (DST), while respondent assumed responsibility for the transfer tax and registration fee.
- Respondent claimed to have been paying real property taxes since 1997 and alleged failure of petitioner corporation to deliver possession and pay taxes as agreed.
- Judicial Proceedings
- Respondent filed a Complaint for Specific Performance on April 7, 2015, docketed as Civil Case No. R-QZN-15-03231-CV, to compel petitioner corporation to comply with its obligations under the Deed. The case was raffled to Branch 95-RTC (Br. 95-RTC).
- Two weeks later, on April 21, 2015, respondent filed a separate Petition for Mandamus (mandamus case) docketed as Civil Case No. R-QZM-15-03669-CV before Branch 76-RTC (Br. 76-RTC). This petition questioned the substitution of TCT No. 185260 with two derivative titles (TCT Nos. 004-2015001698 and 004-2015001699) allegedly irregularly issued by the Register of Deeds (RD) of Quezon City.
- Attempts to serve summons in the specific performance case at petitioner corporation’s purported principal office at 6th Floor, PBCom Building, Ayala Avenue, Makati, failed twice as the building managers confirmed the company did not occupy that space.
- Respondent filed a motion for service of summons by substituted service (publication), which Br. 95-RTC granted on June 9, 2015.
- Conversely, in the mandamus case, summons was served through a front desk representative at the same PBCom office on May 11, 2015, who refused to sign acknowledgment. Br. 76-RTC declared summons valid and subsequently rendered judgment in favor of respondent on June 16, 2015 without petitioner’s answer.
- Petitioner corporation filed a motion for reconsideration in the mandamus case on July 1, 2015, challenging the validity of summons service; Br. 76-RTC granted the motion to reconsider on April 21, 2016, setting aside the prior decision and ordering proper service of summons.
- Meanwhile, petitioner corporation was declared in default in the specific performance case on July 12, 2016. Br. 95-RTC rendered a default judgment in favor of respondent on October 21, 2016, ordering petitioner corporation to pay CGT and DST and deliver possession over the property.
- Respondent filed an omnibus motion on October 27, 2016 to cancel the derivative titles and reinstate TCT No. 185260 annotated with the Deed of Sale; this motion was partly granted on December 13, 2016. The decision became final and executory on December 12, 2016.
- Writ of Execution issued on April 24, 2017 directed enforcement of both the October 21, 2016 decision and the December 13, 2016 order.
- The Deputy RD of Quezon City sought a legal opinion from the Land Registration Authority (LRA) regarding the implementation of the writ. LRA, through its Task Force, declared both the canceled TCT No. 185260 and its duplicate copies as authentic and genuine. The RD filed a manifestation stating inability to comply with the order to cancel existing titles and issue a new one, citing the Torrens system’s protection against collateral attacks on certificates of title.
- Br. 95-RTC issued an order to show cause why the RD should not be cited in contempt for noncompliance.
- Respondent moved to withdraw the mandamus petition, citing overlapping reliefs with the specific performance case. Petitioner corporation opposed, alleging forum shopping by respondent.
- Br. 76-RTC dismissed the mandamus case with prejudice for forum shopping on October 18, 2017; the Court of Appeals (CA) affirmed on November 16, 2018.
- Petitioner corporation filed a petition for certiorari with the CA docketed as CA-G.R. SP No. 150941 assailing the decision and execution in the specific performance case on grounds of invalid service of summons by publication and grave abuse of discretion by the trial court judge.
- The CA denied the petition on June 1, 2018, ruling that the proper remedy would have been a petition for annulment of judgment; it also found that service of summons by publication was valid.
- Petitioner corporation filed a motion for reconsideration, which the CA denied on February 26, 2019.
- Petitioner corporation elevated the case to the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court.
Issues:
- Whether petitioner corporation properly invoked Rule 65 certiorari as against the assailed judgment in the specific performance case despite the CA holding that Rule 47 annulment of judgment was the proper remedy.
- Whether the service of summons by publication in the specific performance case was valid and whether the trial court acquired jurisdiction over petitioner corporation.
- Whether the trial court committed grave abuse of discretion in expanding the scope of the writ of execution issued in the specific performance case beyond the reliefs prayed for and granted in the decision.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)