G.R. No. L-23004 - Makati Stock Exchange, Inc. vs. Securities and Exchange Commission

April 5, 1991: The Republic of the Philippines, through the Solicitor General, filed a Complaint before RTC Branch 8, Davao City (Civil Case No. 20,665-91) to cancel Free Patents Nos. XI-I 4093, XI-I 4362 (Leonora Gaspar) and XI-I 4094, XI-I 4361 (Florencio Gaspar) and their corresponding Original Certificates of Title (OCTs) for fraud and misrepresentation; and to revert the lands to the government.
April 20, 1999: RTC Branch 8 rendered judgment granting cancellation of the patents and OCTs, ordering reversion of the lots to the State, surrender and cancellation of duplicate title copies, and enjoining the Spouses Gaspar from possession or ownership acts.

Spouses Gaspar appealed to the Court of Appeals (CA G.R. CV No. 64921); January 5, 2011 CA Decision affirmed; July 14, 2011 motion for reconsideration denied. Leonora Gaspar’s petition for certiorari (G.R. No. 197918) was denied by the Supreme Court on February 6 and June 27, 2012; Entry of Judgment issued August 23, 2012.
April 7, 2014: During execution of the April 20, 1999 Decision, the Republic moved to cancel all derivative Transfer Certificates of Title (TCTs) emanating from the void patents and OCTs.

June 30, 2015: RTC Branch 8 issued an Order canceling the Free Patents and OCTs and specified derivative TCTs (including Nos. T-304045, T-304046, T-304047, T-304048, T-304049, T-304050, T-304051, T-304052, T-304053, T-304054, T-146-2011006573, T-146-2013003191, T-454798, T-454799), directing surrender and cancellation of titles and reversion of lots.
Petitioners (petitioner-owners of TCT Nos. T-304045, T-304046, T-304047, T-304048, T-304050) filed a Rule 47 petition for annulment of judgment before the CA (CA-G.R. SP No. 08294-MIN), alleging lack of jurisdiction and denial of due process, as they were not parties to the original case.

July 27, 2018: CA Resolution dismissed the petition for annulment, holding the June 30, 2015 Order to be an execution order under the RTC’s residual authority (Rule 135, Sec. 6) and not a final order under Rule 47.
April 30, 2019: CA denied motion for reconsideration. Petitioners filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Whether the June 30, 2015 RTC Order is a “judgment, final order or resolution” subject to annulment under Rule 47.
Whether petitioners, not original parties, may invoke Rule 47 when ordinary remedies are unavailable.

Whether the RTC acquired jurisdiction over petitioners to cancel their derivative titles.
Whether petitioners were deprived of property without due process.

Whether the RTC’s residual authority under Rule 135, Section 6, justifies issuance of the June 30, 2015 Order.
Whether the CA-Twenty-Second Division properly applied the CA-Twenty-Third Division’s ruling in Hsi Pin Liu v. Republic (CA-G.R. SP No. 07590-MIN) under the doctrine of stare decisis.