Case Summary (G.R. No. 182136-37)
Background of the Case
The DE GUZMANS owned two lots in Greenhills, San Juan, Metro Manila, covered by Transfer Certificates of Title (TCT) Nos. 9052 and 9053. In need of funds for a political campaign, they executed a deed of sale on April 10, 1987, in favor of Mario and Erlina Siochi (the SIOCHIS), who later sold these properties to Jayme and Evelyn Uy (the UYS). The DE GUZMANS initiated Civil Case No. 56393 seeking annulment of these transactions on grounds that the initial deed constituted an equitable mortgage rather than a sale, which precluded the SIOCHIS from selling the properties without their consent.
Trial Court's Decision
On December 28, 1990, the Regional Trial Court (RTC) ruled in favor of the DE GUZMANS, recognizing their rights over the properties and nullifying the subsequent sales and lease. The trial court ordered the return of the properties to the DE GUZMANS and the cancellation of titles held by the UYS. Following appeals, the Supreme Court upheld this decision on June 21, 1993.
Subsequent Actions and BON-MAR’s Claims
BON-MAR filed Civil Case No. 67315 in 1999 against the UYS and the Registrar of Deeds, claiming that it purchased the subject lots from the GARCIAS, who acquired them from the DE GUZMANS. BON-MAR alleged that the title transfer to the UYS was based on forgeries. The trial court eventually ruled in favor of BON-MAR, declaring it the legitimate owner of the properties.
Writ of Execution and Intervention Issues
The DE GUZMANS moved for a writ of execution based on their case, while BON-MAR sought to intervene, claiming it was a necessary party with valid legal interest. However, the RTC denied BON-MAR's motion, resulting in an execution of the writ favoring the DE GUZMANS. BON-MAR then appealed, asserting its ownership claims and the need to consider its interests in the ongoing case.
Court of Appeals and Supreme Court's Overview
The Court of Appeals denied BON-MAR’s appeal on the basis that it was a stranger to the litigation in Civil Case No. 56393. However, with the finality of BON-MAR’s ownership claim from Civil Case No. 67315, the Supreme Court determined that BON-MAR should be allowed to intervene as a necessary party to resolve the remaining issues effectively.
Rulings on BON-MAR’s Intervention
The Supreme Court ruled that BON-MAR was indeed entitled to intervene in Civil Case No. 56393 since it could demonstrate legal interest in the ownership of the disputed properties. The Court emphasized that adjudication should address the rightful ownership and that the claims connected with the past transactions were related to BON-MAR’s rights.
Writ of Possession and DE GUZMANS' Entitlement
The Court denied the DE GUZMANS a writ of possession while BON-MAR’s claims were unresolved, acknowledging that giving possession to the DE GUZMANS without consideration of BON-MAR’s rights could lead to futility
...continue readingCase Syllabus (G.R. No. 182136-37)
Background of the Case
- This case involves a petition for review on certiorari by Bon-Mar Realty and Sport Corporation (BON-MAR) challenging the November 14, 2007 Decision and March 17, 2008 Resolution of the Court of Appeals.
- The consolidated cases arose from two Court of Appeals cases: CA-G.R. SP No. 94945, where BON-MAR's petition to intervene in Civil Case No. 56393 was denied, and CA-G.R. SP No. 97812, where the Court of Appeals granted the de Guzmans' leave to intervene in a contempt proceeding against the Registrar of Deeds of San Juan.
- The case focuses on the ownership and title of two lots located in Greenhills, San Juan, Metro Manila, originally owned by the Spouses Nicanor and Esther de Guzman (the DE GUZMANS).
Factual Antecedents
- The DE GUZMANS borrowed money from Mario and Erlina Siochi (the SIOCHIS) and executed a deed of sale dated April 10, 1987, as collateral, which the SIOCHIS used to cancel the original titles (TCT Nos. 9052 and 9053).
- The SIOCHIS later sold the property to Jayme and Evelyn Uy (the UYS), who then entered into a lease agreement with Roberto Salapantan.
- The DE GUZMANS filed Civil Case No. 56393 seeking annulment of the sales and reconveyance of the properties.
- The Regional Trial Court ruled that the agreement between the DE GUZMANS and the SIOCHIS was a mere equitable mortgage, leading to the cancellation of the sales to the SIOCHIS and the UYS.
Judicial Decisions and Appeals
- The trial court's decision was affirmed b