Case Summary (G.R. No. 193078)
Factual Background
On April 11, 2000, Gueco purchased the subject properties from B. Sta. Rita for P1,000,000.00, as documented in a Deed of Absolute Sale. However, B. Sta. Rita later asserted that this transaction was, in fact, a conditional sale amounting to P25,000,000.00. B. Sta. Rita claimed Gueco had only made partial payments and that the sale documentation was intended for obtaining a loan, contesting Gueco's assertion that she owned the titles outright.
Legal Proceedings Initiated by Gueco
In October 2001, Gueco filed a petition for the surrender of the titles, leading to Civil Case No. 9245, which was assigned to RTC Branch 64. B. Sta. Rita filed an Answer, contesting the nature of the sale and asserting possession of the properties until Ben Sta. Rita’s death. Concurrently, the Sta. Ritas, as heirs, filed a derivative action in Civil Case No. 9532 for the reformation and rescission of the sale, claiming the deed was not reflective of the true agreement.
Derivative Suit and Interventions
The Sta. Ritas attempted to intervene in the surrender case, which RTC Branch 64 permitted, but their motion to dismiss was later presented by Gueco based on their alleged lack of standing. RTC Branch 63 ruled in favor of the Sta. Ritas' intervention. Subsequently, the reformation action was dismissed by the Court of Appeals for lack of standing, which a motion for reconsideration did not successfully overturn.
RTC Decision on Sale Transaction
On December 8, 2005, RTC Branch 63 ruled in favor of Gueco, rescinding the sale and ordering the return of P1,000,000.00 with interest. The court found that the intent of the parties was not to create a definitive sale but a conditional one that had not reached completion.
Court of Appeals Ruling
The Court of Appeals, in its January 21, 2010 decision, reversed the RTC ruling, stating that the dismissal of the reformation case affected the jurisdiction and standing of the parties involved in related issues. The CA concluded that the rescission was erroneous considering the principles of res judicata, as the issue had already been resolved in the dismissed case.
Present Petition for Review
Arlene Sta. Rita Kanapi, as the petitioner, argued that her standing had not been affected since she had filed a complaint-in-intervention. She contested the application of res judicata, claiming there was no identity of parties, and suggested that the sale should instead be deemed an equitable mortgage due to the low consideration involved.
Court’s Analysis and Ruling
The Supreme Court dismissed the petition on significant grounds. Firstly, it determined that Arlene and the heirs lacked le
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Case Overview
- This case involves a petition for review on certiorari challenging the Decision dated January 21, 2010, and the Resolution dated July 26, 2010 of the Court of Appeals (CA) in CA-G.R. CV No. 87000.
- The CA's decision reversed and set aside the Joint Decision dated December 8, 2005 of the Regional Trial Court (RTC) Branch 63 in Tarlac City, which had upheld a Deed of Absolute Sale between petitioners B. Sta. Rita & Co., Inc. and respondent Angeline M. Gueco.
Facts of the Case
- On April 11, 2000, Gueco purchased four parcels of land from B. Sta. Rita for P1,000,000.00, documented by the subject deed.
- Gueco filed a petition in October 2001 for the surrender of titles against B. Sta. Rita, its corporate secretary, and the Tarlac Registry of Deeds, leading to Civil Case No. 9245.
- B. Sta. Rita and Edgardo Kanapi claimed the sale was conditional, asserting Gueco only paid P1,565,000.00 and that they remained in possession of the properties until 2001.
- In July 2003, the Sta. Ritas, as heirs of Ben Sta. Rita, filed a derivative suit for reformation and rescission of contract against Gueco, which became Civil Cas