G.R. No. 219984 - Valencia Farmers Cooperative Marketing Association, Inc. vs. Heirs of Cabotaje

Petitioner FACOMA, represented by its Board of Directors (notably Board Chairman David M. Porticos), instituted an action for quieting of title, recovery of ownership and possession of a parcel of land, and for damages against respondents, the Heirs of Amante P. Cabotaje, and Francisco Estrada.
The action was filed before the Regional Trial Court (RTC) of Malaybalay City, Branch 8, under Civil Case No. 2663-97.

On December 3, 2010, the RTC delivered a Decision in favor of petitioner FACOMA which included:

An order for the annulment and cancellation of the deed of sale executed by Francisco Estrada in favor of Amante Cabotaje.
An order directing the defendants to desist from interfering with FACOMA’s right to ownership and possession.
An order for the Register of Deeds to restore the Certificates of Title in favor of FACOMA.

Respondents (Heirs of Cabotaje) contested the RTC ruling by filing a Motion for Reconsideration, raising three primary contentions:

That petitioner FACOMA lacked legal personality (as argued in the defense by Francisco Estrada).
That the deed of sale, allegedly admitted during the pre-trial and executed before a Notary Public, was regular and valid.
That the sale by Francisco Estrada to the respondents was binding and valid.

On February 3, 2011, the RTC denied the respondents’ Motion for Reconsideration.
Subsequently, on February 25, 2011, the respondents filed a Notice of Appeal.

The RTC, deeming the Motion for Reconsideration pro forma (as it raised no new issues), issued a Resolution on April 4, 2011, which denied the Notice of Appeal for being filed out of time.
As a result, respondents filed a Certiorari Petition under Rule 65 of the Rules of Court on June 6, 2011, later amended on July 25, 2011, alleging grave abuse of discretion by the RTC in denying their appeal.
During the pendency of the Certiorari Petition before the Court of Appeals (CA), petitioner FACOMA advanced a Motion for Execution of Judgment. Although initially denied, a subsequent Motion for Reconsideration led the RTC to grant execution on December 13, 2011.
The CA, in its Decision dated March 27, 2014 and accompanying Resolution dated August 13, 2015, set aside the RTC Resolution and ordered the RTC to give due course to the respondents’ Notice of Appeal.

Petitioner FACOMA filed a Motion for Reconsideration on April 24, 2014, which was eventually denied by the CA.
Further, petitioner FACOMA sought early resolution of the appeal through a Motion for Early Resolution filed on February 23, 2016; the respondents filed comments and compliance submissions, and FACOMA answered with a reply on May 25, 2017.
This culmination of proceedings led to the instant Petition for Review on Certiorari by petitioner FACOMA assailing the CA’s decisions.

Whether the CA erred in holding that the Certiorari Petition filed by respondents targeted the RTC’s Resolution dated April 4, 2011 – which denied the respondents’ Notice of Appeal – and not the RTC’s Decision dated December 3, 2010 establishing FACOMA’s favorable judgment.
Whether the CA erred in determining that the respondents’ Motion for Reconsideration was not a pro forma motion, thereby rendering the Notice of Appeal timely filed despite appearing three days late.
Whether the execution of the RTC Judgment, granted upon petitioner FACOMA’s Motion for Execution of Judgment, rendered the instant case moot and academic, precluding a justiciable controversy.