Case Summary (G.R. No. 186522)
Facts of the Case
The controversy originated when Rowena filed a petition with the Regional Trial Court (RTC) on 18 November 1999, seeking the surrender of TCT No. 228526 from Lolita, whom she alleged refused to return the title entrusted to her before Rowena went to Saudi Arabia in June 1997. Rowena claimed ownership of the 50-square meter property based on a Deed of Absolute Sale dated 19 March 1993, evidencing that she bought it from Domingo Delos Santos. However, Domingo had also sold the remaining 550 square meters of the property to Lolita on the same day.
Sequence of Cases
On 17 May 2000, Lolita and Domingo initiated a separate action against Rowena, seeking annulment of the Deed of Sale and the cancellation of the related TCT. They alleged that Rowena had forged their signatures in documents to present a false claim to the land. Rowena responded by asserting that she had an understanding with them not to disclose her involvement due to pending approvals from the Bureau of Lands.
Court Proceedings
Lolita filed a motion to suspend LRC Case No. 1322 based on the ongoing proceedings of Civil Case No. 2257. However, the RTC denied the motion, citing the earlier filing of LRC Case No. 1322. The cases were eventually consolidated for trial. On 28 August 2006, the RTC ruled against Rowena, citing evidence of forgery and declaring the Deed of Sale and Agreement of Subdivision null and void, ordering the cancellation of TCT No. 228526.
Court of Appeals Findings
Rowena appealed the RTC's decision, arguing it was rendered in error as it dismissed LRC Case No. 1322 without addressing her claims of forum shopping. The Court of Appeals (CA) ruled against her, affirming that the dismissal was justified and clarifying the implications of submitting a false certificate of non-forum shopping did not warrant automatic dismissal unless there was clear evidence of deliberate forum shopping.
Legal Issues Raised
Rowena's petition raised several issues, including claims of forum shopping, the non-inclusion of an indispensable party in the complaint, and a challenge to the rulings of the RTC regarding evidence and good faith purchase claims. The p
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Case Information
- Court: Supreme Court of the Philippines
- Date: September 02, 2015
- G.R. No.: 186522
- Division: Second Division
- Decision Writer: Justice Brion
Background of the Case
- This case involves a petition for review on certiorari stemming from decisions of the Court of Appeals regarding Civil Case No. 2257 and LRC Case No. 1322.
- Rowena C. De Leon filed a petition against Lolita Chu, seeking the return of the Transfer Certificate of Title (TCT) No. 228526 for a 50-square meter parcel of land.
Factual Antecedents
- On November 18, 1999, Rowena alleged that she had entrusted the title to Lolita before leaving for Saudi Arabia in June 1997, and Lolita refused to return it.
- Rowena claimed to have purchased the property from Domingo Delos Santos as evidenced by a Deed of Absolute Sale dated March 19, 1993.
- Domingo had sold a larger portion of land, including the 50-square meter lot, to Lolita on December 17, 1990.
- A dispute arose, leading Domingo and Lolita to file for annulment of the Deed of Sale and cancellation of TCT No. 228526, alleging Rowena forged their signatures.
Legal Proceedings
- The Regional Trial Court (RTC) initially ruled in favor of Lolita and Domingo, declaring both the Deed of Sale and the Agreement of S