Case Summary (G.R. No. 188029)

Case Background

• Petitioner: Arturo C. Calubad
• Respondents: Billy M. Aceron and Oliver R. Soriano
• Court: Supreme Court of the Philippines
• Date of Decision: September 02, 2020

Nature of the Case

• This case involves a Petition for Review on Certiorari challenging the resolutions of the Court of Appeals which dismissed Calubad's Petition for Annulment of Final Resolution under Rule 47 of the Rules of Court.

Legal Proceedings Overview

• Initial Agreements:

  • An unnotarized Deed of Conditional Sale was executed in April 1992 between Aceron and Oliver for a property in Quezon City.
  • The property was transferred to Oliver, who subsequently attempted to cancel the sale due to non-payment by Aceron.

• Court Rulings:

  • The Regional Trial Court (RTC) ruled in favor of Aceron in 1996, mandating Oliver to execute a Deed of Absolute Sale.
  • Oliver's appeal was denied, making the RTC decision final in 2003.
  • In 2004, the RTC executed a resolution granting Aceron's motion for ownership transfer of the property.

Petition for Annulment

• Grounds for Annulment:

  • Calubad claimed he was not a party to the original case and that there was an absence of notice regarding the pending case, which he argued constituted extrinsic fraud.

• Court of Appeals Rulings:

  • The CA dismissed Calubad's petition, citing available remedies other than annulment and lack of extrinsic fraud.
  • Calubad's motion for reconsideration was denied in 2009.

Key Legal Issues

1. Jurisdiction Matters:

   • Whether the appellate court could cancel annotations related to Calubad's mortgage despite him not being a party in the original case.

2. Available Remedies:

   • The appellate court found that Calubad had other legal remedies available, rendering the annulment petition improper.

Court's Findings

• Jurisdiction Confirmation:

  • The RTC acted within its jurisdiction when issuing the resolution that divested Oliver of ownership, reaffirming the finality of the earlier decision in Civil Case No. Q-93-18011.

• Extrinsic Fraud:

  • No extrinsic fraud was found that deprived Calubad of his rights to intervene in the original case.

• Binding Nature of Judgments:

  • Calubad, as a successor-in-interest, is bound by the judgment against Oliver, as he derived his interest after the original case had become final.

Legal Principles Established

• Annulment of Judgment:
  • This is an equitable remedy reserved for exceptional cases where no other remedies are available.
  • Grounds include extrinsic fraud and lack of jurisdiction, neither of which applied in this case.

Conclusion of the Court

• The Supreme Court affirmed the CA's resolutions, denying Calubad’s petition. The decision underscores the finality of judgments and the binding nature of court rulings on successors-in-interest.

Key Takeaways

• Calubad's claim was denied as he failed to demonstrate extrinsic fraud or lack of jurisdiction.
• Th...continue reading

Case Syllabus (G.R. No. 188029)

Case Background

• The case revolves around a petition for annulment of final resolutions by Arturo C. Calubad against Billy M. Aceron and Oliver R. Soriano.
• The Court of Appeals dismissed Calubad's petition on September 19, 2007, and May 29, 2009, stating that other remedies were available to him and that no extrinsic fraud occurred.

Antecedents

• In April 1992, Aceron and Soriano entered into an unnotarized Deed of Conditional Sale for a parcel of land in Quezon City valued at P1.6 million, with the title still in the name of the Spouses Soriano.
• Aceron was allowed to possess the property upon payment of P300,000.
• By October 1992, the title was reconstituted in Soriano's name, but he later attempted to cancel the sale.
• Aceron initiated a legal complaint in 1993 demanding the execution of a Deed of Absolute Sale after Soriano's cancellation attempt.
• The RTC ruled in favor of Aceron in December 1996, leading to a series of appeals and a final ruling affirming Aceron’s rights by August 2003.

Subsequent Events

• After the court's decision, TCT No. N-253373 was issued in Soriano's name, who later mortgaged the property to Calubad for P1.6 million.
• Aceron continued efforts to execute the court's decision, leading to further litigation as Soriano’s title was encumbered due to the mortgage.
• Aceron filed an Omnibus Motion in October 2004, which...continue reading