Case Summary (G.R. No. 160994)
Applicable Law
The case is adjudicated under the 1987 Philippine Constitution and relevant provisions of the Civil Code of the Philippines, particularly concerning co-ownership, partition, and the effects of judicial compromises.
Background of the Cases
The petitioners, Wilfredo and Swarnie Aromin, initiated Civil Case No. 921-BG against Paulo Floresca for specific performance related to the sale of land. The couple claimed that they purchased portions of the property from Paulo but faced legal challenges from his siblings—Victor, Juanito, and Lilia—asserting their shared ownership of the land.
Proceedings and Rulings
The court a quo (Regional Trial Court Branch 67, Bauang, La Union) ruled in favor of the Aromins, declaring them buyers in good faith and not bound by a prior compromise agreement (Civil Case No. 832-BG) that partitioned the same property among Paulo and his siblings. The court criticized the siblings for their lack of action regarding their alleged co-ownership rights during the sale and discounted their claims against the Aromins.
Appeal to the Court of Appeals
Subsequently, the respondents appealed this decision. The Court of Appeals reversed the ruling of the court a quo, enforcing the judgment based on the compromise agreement in Civil Case No. 832-BG, ratifying that the property was co-owned by the siblings and Paulo. The appellate court held that the Aromins were negligent in failing to investigate the ownership status of the property and thus could not claim they were buyers in good faith.
Key Findings of the Court of Appeals
The appellate court articulated that a judicial compromise is binding and constitutes res judicata, specifically asserting that the subjects of co-ownership had already been adjudicated in prior proceedings. It emphasized that the sale's validity only extended to Paulo's one-half share and that the Aromins could not claim full ownership as they had initially thought. The court also criticized the Aromins for their ignorance of the existing legal encumbrances, reflecting negligence on their part.
Denial of Reimbursement Claims
Further, the Court of Appeals determined that Paulo was liable for moral damages and attorney’s fees to his siblings given the fraudulent nature of his actions in handling the property. The appellate court declined to reimburse the Aromins for any part of the purchase price, emphasizing that they bore the responsibility for conducting due diligence.
Supreme Court Ruling
Upon further appeal by the Aromins to the Supreme Court, the original rulings by the Court of Appeals were affirmed in their entirety. The Court reiterated that the compromise agreement'
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Background of the Case
- The case revolves around a petition for review on certiorari filed by spouses Wilfredo and Swarnie Aromin against the decision of the Court of Appeals dated June 6, 2003.
- The appellate court reversed the decision of the Regional Trial Court (RTC) of Bauang, La Union, Branch 67, which had ruled in favor of the Aromins regarding ownership of certain parcels of land.
- The case involved three civil cases concerning the same property and parties: the Aromins and the Floresca siblings (Paulo, Victor, Juanito, and Lilia).
Civil Cases Involved
- Civil Case No. 921-BG: An action for specific performance filed by the Aromins against Paulo Floresca. The Aromins claimed ownership of parcels of land sold by Paulo but not registered with the Register of Deeds.
- Civil Case No. 938-BG: An action for quieting of title filed by the Aromins against the Floresca siblings and Paulo, asserting their ownership and seeking to restrain execution of a prior judgment.
- Civil Case No. 965-BG: An action for annulment of sale filed by the Floresca siblings against Paulo and the Aromins, claiming co-ownership of the property.
Facts of the Case
- The Aromins purchased portions of land from Paulo Floresca through multiple unregistered deeds of sale from 1990 to 1992, totaling 98,257 square meters.
- The Floresca siblings claimed that the properties were co-owned and that a prior judgment in a partition case (Civil Case No. 832-BG) declared them owners of a half share of the property.
- The court a quo initially ruled in favor of the Aromins, recognizing them as buyers in good faith and declaring the judgment in Civil Case No. 832-