Case Summary (G.R. No. 183906)
Summary of Facts
In 1976, Investco, Inc. entered a contract to sell certain properties to Solid Homes, Inc. After Solid Homes defaulted on payments, Investco initiated legal action for specific performance and damages. During this litigation, Investco sold the properties to AFPMBAI, which led to the issuance of new titles. Solid Homes then filed suit against Investco, AFPMBAI, and the Register of Deeds for damages and lis pendens notation. The Supreme Court eventually determined AFPMBAI to be a buyer in good faith, ordering the cancellation of Solid Homes' lis pendens.
Procedural History
On August 26, 2003, Solid Homes filed an action to cancel AFPMBAI’s titles; however, the RTC, citing res judicata due to prior final decisions, dismissed Solid Homes' complaint on January 23, 2004. Solid Homes’ motion for reconsideration was denied, leading to a second motion that was also rejected as a prohibited pleading. Eventually, Solid Homes filed a petition for relief from the RTC's dismissal, claiming extrinsic fraud in actions involving AFPMBAI and Investco. The RTC granted this petition on July 18, 2008.
Petition for Prohibition and Mandamus
AFPMBAI petitioned the Supreme Court for prohibition and mandamus, claiming the RTC’s acceptance of Solid Homes’ petition was inappropriate. The petition highlighted several deficiencies: the timing of Solid Homes' filing was beyond allowed periods, it lacked a necessary affidavit of merit, and the alleged fraud did not meet the statutory definition entailed in the Rules of Civil Procedure.
Issues Presented
The issues revolve around procedural deficiencies in Solid Homes' petition for relief, particularly regarding the timeliness of filing, adequacy of supporting documentation, applicability of the alleged extrinsic fraud, the res judicata effect of previously resolved issues, and the propriety of a notice of lis pendens connected to a petition for relief from judgment.
Court Rulings
The Court held that AFPMBAI's failure to file a motion for reconsideration did not bar the petition, allowing the Supreme Court to address the matter as it was a question of law and in the interest of justice. Confirming Solid Homes’ filing was late, the Court ruled that Solid Homes' petition for relief did not follow the required timelines set by Rule 38.
Analysis of Extrinsic Fraud
Regarding the alleged extrinsic fraud proposed by Solid Homes, the Court concluded that such claims must relate to actions obstructing a party's right to be heard in a prior case, rather than merely contesting the merits. Since the central is
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Overview of the Case
- The case involves a petition for prohibition and mandamus filed by AFP Mutual Benefit Association, Inc. (AFPMBAI) against the Regional Trial Court (RTC) of Marikina City and Solid Homes, Inc.
- The primary issue is the RTC's order that gave due course to Solid Homes' petition for relief from judgment, which sought to re-litigate issues already adjudicated with finality.
Facts of the Case
- In 1976, Investco, Inc. entered into a contract to sell properties to Solid Homes but Solid Homes defaulted on payments.
- Investco subsequently sued Solid Homes for specific performance and damages.
- During the pending case, Investco sold the properties to AFPMBAI, which received new certificates of title after full payment.
- Solid Homes filed an action against the Register of Deeds, AFPMBAI, and Investco for annotation of lis pendens and damages.
- The Supreme Court ruled in favor of AFPMBAI, declaring it a buyer in good faith and ordering the cancellation of Solid Homes' notice of lis pendens.
- Solid Homes later filed another action to cancel AFPMBAI's certificates of title, which was dismissed by the RTC on grounds of res judicata.
- Despite the dismissal, Solid Homes filed a petition for relief from judgment, alleging extrinsic fraud by Investco and AFPMBAI.
- The RTC granted Solid Homes' petition, prompting AFPMBAI to file a petition for prohibition and mandamus.
Issues Presented
- Whether Solid Homes' petition for relief from judgment was technically deficient.
- Whether