G.R. No. L-21642 - Social Security System vs. Davac

The petitioner, Alfonso Vergara, filed a petition for prohibition with mandatory injunction on January 4, 1971.
He sought to restrain the enforcement of an order of execution of a Court of Appeals decision dated June 20, 1967 (CA-G.R. No. 31186-R) which reversed a trial court ruling in the underlying controversy.
The underlying dispute originated from the case “Abraham Rugue vs. Alfonso Vergara, et al.”, where Rugue, the plaintiff in the earlier action, claimed to be the rightful owner of Lot No. 9, Block No. 12 of the Tuason Estate, while Vergara intervened asserting a superior or preferential right.

On September 30, 1949 (with facts recited as early as September 16 or 30, 1948), Abraham Rugue purchased a portion of the Tuason Estate under a contract of sale (Kasunduan sa Pagbibili) executed by the Kapisanan “Ang Buhay, Inc.”

Rugue duly and regularly paid the installments required under the contract.
The lot’s area had been reduced due to the widening of the street, yet Rugue completed the payment obligations, thereby entitling him to the document of sale for the property.

Before the necessary transfer document could be executed by the Land Tenure Administration (LTA), Alfonso Vergara intervened by claiming a preferential right over the lot.

An investigation by the LTA led to awarding the sale in favor of Rugue initially.
However, a subsequent appeal was made by Vergara resulting in a reversal by the Office of the President (executed via Executive Secretary Juan Pajo on June 12, 1958 and later by Natalio Castillo on February 12, 1960), which awarded the contract to Vergara.

Payment of back installments and the completion of the purchase price by Rugue.
Rugue’s acts of physical possession and improvements he made on the lot, including fencing, barbed wire installation, stone and gravel filling, and the erection of a makeshift shelter.
Differences regarding Rugue’s status as a bona fide tenant, claimed by Vergara, as well as Rugue’s alleged lack of immediate need for the property.

The trial court initially dismissed Rugue’s complaint for annulment of the sale and specific performance, though it ordered the LTA to refund and reimburse Rugue for his payments and improvements.
The Court of Appeals reversed the trial court’s decision on June 20, 1967, canceling the sale made in favor of Rugue and ordering the reconveyance of the lot to Rugue while imposing costs against Vergara.
Execution of the CA decision was ordered in the lower courts; petitioners (including Vergara) were served with the order on January 20, 1970.
Alfonso Vergara, through subsequent motions and petitions:

Contended that he was not adequately notified of the CA decision due to his former counsel’s alleged negligence.
Filed a petition for relief from judgment and various motions for reconsideration on distinct grounds such as the alleged failure of Rugue to fulfill contractual conditions and the appropriateness of awarding the lot to Vergara.

The Court of Appeals denied Vergara’s petitions for relief and motions for reconsideration on multiple occasions.
Finally, Vergara filed a petition for review by certiorari (G.R. No. L-32309) and later a petition for prohibition alleging grave abuse of discretion and excess of jurisdiction by the appellate court.

Vergara argued that by reviewing and effectively annulling the decisions of Executive Secretaries Pajo and Castillo—decisions which had long become final and executory—the Court of Appeals acted beyond its jurisdiction.
He further alleged that the appellate court revisited settled factual determinations, thereby relitigating issues that had been definitively resolved in earlier proceedings.
The petitioner contended that his claim for prohibition was justified as a preventive measure against what he characterized as a “patent grave abuse of discretion” by the lower courts, including a misstatement of facts and disregard of the doctrine of res judicata.

Whether the Court of Appeals exceeded its appellate jurisdiction by reviewing and annulling the administrative decisions of Executive Secretaries Pajo and Castillo, decisions that were argued by the petitioner to be final and executory.
Whether the appellate court’s actions amounted to grave abuse of discretion warranting the issuance of a prohibitory writ.

Whether the petitioner’s current petition for prohibition improperly seeks to relitigate issues (both factual and legal) that had been adjudicated in earlier proceedings.
Whether the principle of res judicata bars the petitioner from raising issues already resolved, particularly those concerning the validity of the sale and the rightful ownership of the lot.

Whether prohibition, a preventive remedy designed to restrain acts done without or in excess of jurisdiction, is the proper recourse in this instance given that the contested decision had already been executed and finalized.
Whether the petitioner’s allegations of “mistakes of counsel” and administrative errors are sufficient grounds to invalidate the CA decision through an extraordinary writ.