Case Summary (G.R. No. 207887)
Factual Background
In 1953, Victoriano Domilos acquired a 15,745 sq.m. parcel along Sto. Tomas Road, Baguio City, later transferring rights to his son Lino (1976). Sergio Nabunat and family illegally occupied and built on the land in 1974 and 1976, prompting Lino’s forcible entry suit. The City Court (1977) and RTC (1979) ordered ejectment and demolition.
Compromise Agreement and Subsequent Sales
On November 17, 1986, Lino and Palichang entered a compromise agreement dividing the land into five 3,000-sq.m. portions among themselves and others, including Rupisan. Between 1987 and 1989, Lino, Nabunat, and Palichang sold various subdivided parcels—among these sales, spouses Pastor and Joseph Pastor acquired two parcels (232 sq.m., 229 sq.m.) and one 600-sq.m. lot.
Revival of Execution and Revocation of Compromise
On May 9, 1989, Lino filed a motion for a 4th alias writ of execution to enforce the 1977 City Court decision. On May 15, 1989, Lino and Palichang executed an agreement revoking the November 1986 compromise. The writ issued May 20, 1989 led to demolition of improvements on Pastor properties.
Annulment Suit before the RTC
The Pastors filed Civil Case No. 1784-R (June 26, 1989) praying for annulment of the writ, cancellation of the revocation, recovery of possession, and damages. They alleged Lino wrongfully revoked the compromise to dispossess them. Lino, Palichang, and Nabunat denied liability, challenging jurisdiction and party-status. The Pastors amended to implead the judge and sheriff.
RTC Decision and Resolution
On September 21, 2006, the RTC declared spouses Pastor and Joseph Pastor as rightful owners of the 232-sq.m., 229-sq.m., and 600-sq.m. parcels, ordering peaceful surrender (Civil Case No. 1784-R). It dismissed Rupisan’s joined case (No. 2107-R). On January 22, 2007, the RTC modified its judgment language to reflect that the Pastors “acquired lawful rights…by virtue of a valid conveyance” and upheld the order of possession.
Court of Appeals Ruling
The CA, in G.R. CV No. 89201, on March 26, 2013 dismissed Lino’s appeal and affirmed both the RTC Decision and Resolution. It found no error in the determination of ownership, and awarded costs against the appellants.
Issues Presented
- Alleged failure by RTC and CA to state facts and law clearly (Const. Art. VIII, Sec. 14; Rule 36, Sec. 1).
- Validity of compromise agreement not judicially approved.
- CA’s failure to consider spouses Pastor’s and Joseph’s judicial admissions and alleged bad faith.
- Capacity of buyers in bad faith to challenge revocation of a compromise they did not sign.
- Proper application of Civil Code Art. 1131 (Third-party rights under contracts creating real rights).
Supreme Court’s Analysis: Compliance with Constitution and Rules
The Court held that both RTC and CA sufficiently summarized “essential ultimate facts” and applied pertinent laws and jurisprudence (citing People v. Maguikay). A decision need not discuss every piece of evidence, only those relevant to material issues. The judgments satisfied Article VIII, Section 14 of the 1987 Constitution and Rule 36, Section 1 of the Rules of Court.
Validity of the Compromise Agreement and Third-Party Rights
Under Civil Code Articles 1312, 1315, and 1385, contracts creating real rights bind third-party possessors acting in good faith. The compromise created real rights over subdivided parcels; the Pastors, as good-faith purchasers, lawfully acquired their shares. Revocation of the compromise cann
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Antecedents and Factual Background
- In 1953, Victoriano Domilos acquired possession of a 15,745-sq.m. parcel along Kms. 4–5, Santo Tomas Road, Baguio City.
- In 1974, Sergio Nabunat and his family built a temporary shanty on the property and resided there for three months.
- In February 1976, Victoriano transferred all his rights over the land to his son Lino Domilos.
- In March 1976, Nabunat, his wife Soledad, and his mother-in-law Can-ay Palichang constructed a house on the property without Lino’s consent.
- Lino filed a forcible entry complaint in Civil Case No. 5893 before the City Court of Baguio; the court (1977) and the Court of First Instance (1979) ordered the demolition of Nabunat’s house and the family’s ouster.
- On November 17, 1986, Lino and Palichang executed a compromise agreement dividing the 15,000-sq.m. tract into five portions (3,000 sq.m. each for Lino, Palichang, Nabunat, and Rupisan; and a reserve for Lino) and agreeing to dismiss all related suits.
- Between 1987 and 1989, Lino and Nabunat and Palichang sold portions of their allocated interests to several buyers, including Dorothea L. Pastor (232 sq.m.) and Joseph L. Pastor (600 sq.m.).
- On May 9, 1989, Lino sought to execute the 1977 decision via a fourth alias writ of execution and on May 15, 1989, Lino and Palichang purported to revoke the 1986 compromise agreement.
- On May 20, 1989, the writ resulted in the demolition of some structures belonging to the Pastors.
Procedural History
- June 26, 1989: Spouses Pastor and Joseph filed Civil Case No. 1784-R for annulment of order, revocation of compromise agreement, recovery of possession, and damages before RTC Branch 3, Baguio City.
- They later amended their complaint to implead the judge and the sheriff; the RTC granted leave on December 5, 1991.
- June 10, 1992: Atty. Basilio Rupisan instituted Civil Case No. 2107-R for his share under the compromise agreement.
- September 21, 2006: RTC Branch 61 (Civil Ca