Case Summary (G.R. No. 208928)
Relevant Dates and Procedural History
- Complaint filed: March 19, 2003
- RTC Summary Judgment: September 12, 2006
- CA Decision: September 28, 2012
- CA Resolution denying motion for reconsideration: August 13, 2013
- Supreme Court Decision: July 8, 2015
Applicable Law: 1987 Philippine Constitution; Rules of Court; Civil Code (Articles 970, 971, 982)
Factual Background
Respondents, claiming to be grandchildren and successors-in-interest of Felicisima Udiaan, filed a complaint for declaration of nullity of sale, reconveyance, and damages against petitioner Andy Ang. They alleged that the Deed of Absolute Sale dated July 12, 1993, was executed by an impostor falsely representing herself as Udiaan, who had been deceased for over 20 years at the time of sale. Consequently, the original title (OCT No. T-3593) was canceled, and a Transfer Certificate of Title was issued to petitioner.
Petitioner denied the allegations, asserting good faith purchase based on purported credible representation by the vendor who possessed documents and identification attesting to ownership. Petitioner admitted to paying twice for the property—the initial questionable sale and subsequently acquiring a portion from the Heirs of Alfredo Gaccion who were occupying the land.
Trial Court Ruling (RTC)
The RTC ruled in favor of petitioner, dismissing respondents’ complaint for lack of merit. It held that respondents failed to prove their succession rights over the subject land. Consequently, they were not the real parties in interest entitled to bring the action.
Court of Appeals Ruling
On appeal, the CA affirmed the dismissal of respondents as not being real parties in interest but, with modification, declared the Questioned Deed of Absolute Sale null and void as executed by a person other than Udiaan, who had long been deceased. The CA validated petitioner’s acquisition of a 3,502-sq. m. portion from the Heirs of Gaccion, and apportioned the remaining land among the Heirs of Gaccion and Udiaan’s children.
Issue Before the Supreme Court
Whether the Court of Appeals correctly nullified the sale and distributed portions of the land despite concluding that respondents were not the real parties in interest entitled to pursue the case.
Legal Analysis: Real Party in Interest
Under Section 2, Rule 3 of the Rules of Court, the real party in interest is the individual entitled to the benefits or injured by the judgment. The twofold requirement is that the plaintiff must both possess the material interest and prosecute the action in their own name. The rule serves to prevent litigation by persons without legal standing, avoid multiplicity of suits, and promote judicial economy.
The Civil Code provisions on right of representation (Articles 970 and 982) establish that grandchildren inherit by representation only if their parent (the child of the decedent) predeceased the decedent, was incapacitated, or disinherited. The respondents failed to prove these conditions.
Supreme Court’s Conclusion on Real Parties in Interest
The Supreme Court agreed with the RTC and CA that respondents are not real parties in interest because they did not establish that their mother (Udiaan’s child) predeceased or was incapacitated in a way to entitle them to succeed by right of representation. Consequently, the respondents lacked material interest in the subject land and were not entitled to maintain the suit.
Supreme Court’s Correction of CA’s Substantive Rulings
Given respondents’ lack of real interest, the Supreme Court found that the CA erred in proceeding to adjudicate the substantive issues and declaring the nullity of the Questioned Deed of Absolute Sale. Moreover, the CA’s apportionment of the land to third
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Background and Nature of the Case
- The case involves a petition for review under Rule 45 of the Rules of Court, assailing the Decision dated September 28, 2012, and the Resolution dated August 13, 2013 of the Court of Appeals (CA) in CA-G.R. CV No. 00992-MIN.
- The CA affirmed with modifications a Summary Judgment of the Regional Trial Court (RTC) of Cagayan de Oro City, Branch 38 in Civil Case No. 2003-115.
- The central subject is a 98,851-square meter (sq.m.) parcel of land originally registered under Original Certificate of Title (OCT) No. T-3593 in the name of Felicisima Udiaan (Udiaan).
- The respondents, claiming to be grandchildren and successors-in-interest of Udiaan, challenged the validity of a Deed of Absolute Sale executed between petitioner Andy Ang and an impostor representing herself as Udiaan, regarding the sale of the subject land.
Factual Summary
- Respondents filed a Complaint for Declaration of Nullity of Sale, Reconveyance, and Damages on March 19, 2003, alleging that Udiaan died on December 15, 1972, and could not have validly sold the subject land in 1993.
- The contested sale was predicated on a Deed of Absolute Sale dated July 12, 1993, executed by an impostor, which led to cancellation of the original OCT and issuance of a Transfer Certificate of Title (TCT) No. T-79051 in petitioner’s name.
- Petitioner entered the land in 1997 and used it for livestock business.
- Respondents demanded return of the land, asserting invalidity of petitioner’s ownership.
- Petitioner denied the allegations, asserting he bought the land in good faith for value from a person representing herself as Udiaan, presenting apparent proof of identity and possession of OCT No. T-3593.
- Petitioner also claimed he bought the land anew from the Heirs of Alfredo Gaccion after initially being prevented from entering the property.
- Petitioner maintained he was duped into buying the same land twice and claimed respondents were never in possession nor paid property taxes on the land.
Proceedings and Rulings Below
- The RTC, after pre-trial and submission of memoranda, granted summary judgment in favor of petitioner, dismissing the complaint on the ground that respondents failed to prove their successional rights to Udiaan’s estate and thus were not real parties in interest.
- Respondents appealed to the CA.
- The CA affirmed the RTC decision with modification: it nullified the contested Deed of Absolute Sale due to its execution by a person other than the deceased Udiaan, declared valid the sale to pe