Facts:

• The case involves a land dispute in Poblacion, Sindangan, Zamboanga del Norte.
• In November 1989, Visminda Escol (seller) and Ophelia L. Tuatis (buyer) entered into a Deed of Sale by Installment for a 300-square meter parcel of land.
• The purchase price was PHP 10,000, with a downpayment of PHP 3,000 and the balance to be paid in installments.
• Tuatis claimed to have paid the full amount by February 1990, while Visminda contended that only PHP 4,000 had been paid.
• Tuatis took possession of the land and built a residential building on it.
• In 1996, Visminda refused to sign an absolute deed of sale, leading Tuatis to file a complaint for specific performance with damages.
• The RTC ruled in favor of Visminda, ordering Tuatis to return the land and Visminda to return the PHP 4,000 paid.
• Tuatis' appeal to the Court of Appeals was dismissed due to procedural deficiencies, making the RTC decision final and executory.
• Tuatis then filed a Petition for Certiorari and Mandamus, which was also dismissed by the Court of Appeals.
• The case was elevated to the Supreme Court for resolution.

Issue:

• (Unlock)

Ruling:

• The Supreme Court granted the petition, annulling the RTC's order for the issuance of a writ of execution and the actions taken by the Sheriff to enforce it.
• The Court directed the RTC to conduct further proceedings to determine the facts essential for the proper applicati...(Unlock)

Ratio:

• The Supreme Court found that the RTC's decision was incomplete as it failed to adjudicate the rights of the parties under Article 448 of the Civil Code, which governs the rights of landowners and builders in cases of good faith.
• The Court emphasized that procedural rules should not override substantial justice and that the peculiar circumstances of the case justified setting aside procedural defects.
• Althou...continue reading