Case Summary (G.R. No. 182819)
Background of the Case
This case involves a petition for review on the decision by the Court of Appeals that annulled a prior judgment by the Regional Trial Court in Legazpi City. The conflict centers around ownership of Lot No. 1634-B, with Bulawan claiming ownership based on her purchase from the Yaptengco brothers, who purportedly inherited the property from Yap Chin Cun. Respondent Aquende asserts ownership based on a title he acquired, arguing that the trial court's decision adversely affected him without due process.
Trial Court's Initial Decision
On November 26, 1996, the trial court ruled in favor of Bulawan, declaring her the rightful owner of Lot 1634-B and voiding other titles claiming rights over it. Following this decision, Yap appealed; the appeal was dismissed on July 20, 2001, thus rendering the trial court's decision final and executable. A writ of execution was issued on July 19, 2002.
Aquende's Intervention
Aquende, who learned of the writ indirectly and alleged he had no notice of the litigation affecting his property, filed a Third Party Claim. He argued that he was an indispensable party not brought into the original case and thus the trial court lacked jurisdiction over him. The trial court denied his request, stating it had lost jurisdiction over the case.
Petition for Annulment by Aquende
Aquende subsequently petitioned the Court of Appeals for annulment of the trial court's judgment on the grounds of lack of jurisdiction and extrinsic fraud, asserting that he was not afforded the opportunity to protect his property rights in the initial proceedings. He alleged collusion between Bulawan and the trial judge.
Court of Appeals’ Ruling
The Court of Appeals found merit in Aquende's claims, ruling that he was indeed an indispensable party who should have been impleaded in the original case, rendering the trial court’s decision void. It emphasized that without proper jurisdiction over Aquende, the trial court acted beyond its authority. It reinstated Aquende's title and ordered the earlier cancellation of certificates of title nullified.
Petitioner’s Arguments
Bulawan contended that the Court of Appeals improperly annulled a final decision, arguing that the appellate court could not consider Aquende an indispensable party. She claimed that he was not affected by the ruling since his property was distinct from the subject matter of the original lawsuit.
Supreme Court's Determination
The Supreme Court upheld the appellate court's decision, reaffirming that annulment of judgment is a remedy available regardless of whether the decision had been
...continue readingCase Syllabus (G.R. No. 182819)
The Case
- This case is a petition for review of the Court of Appeals' 26 November 2007 Decision and 7 May 2008 Resolution in CA-G.R. SP No. 91763.
- The Court of Appeals granted respondent Emerson B. Aquende's petition for annulment of judgment and declared the trial court's 26 November 1996 Decision void.
- The petition was filed by Maximina A. Bulawan, who sought to contest the Court of Appeals' ruling.
The Facts
- On 1 March 1995, Bulawan filed a complaint for annulment of title, reconveyance, and damages against Lourdes Yap and the Register of Deeds, referenced as Civil Case No. 9040.
- Bulawan claimed ownership of Lot No. 1634-B covered by Transfer Certificate of Title No. 13733, having purchased it from the Yaptengco brothers, who inherited it from Yap Chin Cun.
- Yap countered that she owned Lot No. 1634-A, asserting that the Yaptengco brothers' claim was void due to a prior ruling in Civil Case No. 5064.
- The trial court ruled in favor of Bulawan on 26 November 1996, declaring her the lawful owner of Lot 1634-B and ordering the cancellation of Yap's title.
- Yap appealed but the Court of Appeals dismissed her appeal on 20 July 2001, and the trial court's decision became final on 7 February 2002.
- In July 2002, the trial court issued a writ of execution which Aquende contested, stating he was unaware of any litigation concerning his property and had not been notified.
- Aquende filed a Third Party Claim and subseque