Case Summary (G.R. No. 125560)

Petition for Review on Certiorari

• The case involves a petition for review on certiorari filed by Eliza Francisco Baggenstos against the Court of Appeals and other respondents.
• The Court of Appeals dismissed Baggenstos' Petition for Annulment of Judgments, Orders, and Writs with Damages due to insufficiency in form and substance.

Antecedents of the Case

• On September 6, 1991, Josefino de Guzman filed a complaint against Baggenstos for P85,000, representing unpaid renovation costs.
• The trial court declared Baggenstos in default for not filing an answer and ruled in favor of De Guzman on December 27, 1991.
• A writ of execution was issued on April 3, 1992, leading to the sale of Baggenstos' property at public auction to Pacifico Magno, Jr. for P153,210.72.

Execution and Subsequent Proceedings

• After the one-year redemption period, an Officer's Deed of Sale was executed in favor of Magno on November 18, 1993.
• Magno filed a petition to compel Baggenstos to surrender the duplicate certificate of title, claiming the default judgment was valid.
• Baggenstos opposed, arguing that the trial court lacked jurisdiction due to improper service of summons.

Trial Court's Orders

• The trial court ruled in favor of Magno, affirming the validity of the substituted service of summons and ordering Baggenstos to surrender the title.
• A Writ of Possession was issued on June 19, 1995, but the sheriff faced difficulties enforcing it due to locked premises.

Attempts to Enforce Writ of Possession

• The sheriff reported being unable to enforce the writ due to locked gates and doors.
• Magno filed a motion for a break-open order, which the trial court granted, leading to further disputes regarding the properties involved.

Baggenstos' Motion for Reconsideration

• Baggenstos filed a motion for reconsideration, asserting that the enforcement actions were improperly directed at her property covered by TCT No. 96923, which was not sold at auction.
• The trial court later amended its orders to clarify that the enforcement should only apply to the vacant lot under TCT No. 171720.

Court of Appeals' Ruling

• Baggenstos filed a Petition for Annulment of Judgments, Orders, and Writs with Damages, which the Court of Appeals dismissed due to procedural defects.
• The Court noted that Baggenstos did not seek to annul the original default judgment but rather the execution processes.

Issues Raised by Baggenstos

• Baggenstos contended that the Court of Appeals erred in dismissing her petition and not declaring the questioned orders void concerning TCT No. 96923.
• She sought annulment of the orders and execution proceedings affecting her property.

Supreme Court's Ruling

• The Supreme Court dismissed the petition as moot, noting that the trial court's judgment had become final and executory.
• The ex...continue reading