Case Summary (G.R. No. 146595)
Applicable Law and Jurisdiction
The applicable law in this case is the 1987 Philippine Constitution, as the decision date is in 2012. The proceedings are governed by the Rules of Court, including Rules 38 and 47, which outline relief from judgment and annulment of judgments, respectively.
Factual Background
On July 24, 1995, respondents entered into a Contract to Sell with EAIC for the purchase of a specified land area, paying a partial amount of ₱545,000. However, EAIC failed to provide the owner’s duplicate certificate of title and the deed of sale as mandated by the agreement. This led respondents to file a civil suit, Civil Case No. 96-177, after annotating an Affidavit of Adverse Claim and a Notice of Lis Pendens on the title of the property.
Proceedings and Initial Rulings
EAIC's attempts for legal representation were hindered due to ineffective service of summons. The court proceedings allowed respondents to present their case ex parte after EAIC did not appear at the pre-trial. The Regional Trial Court (RTC) subsequently ruled in favor of the respondents in a decision dated November 11, 1999, ordering EAIC to comply with the Contract to Sell.
Petition for Relief from Judgment
Approximately seven months post-decision, EAIC, through Raul Gala, filed a Petition for Relief from Judgment claiming extrinsic fraud, specifically that Guia Domingo misrepresented her authority. However, this petition was denied by the RTC as it was filed out of time.
Annulment of Judgment
Following the rejection of the relief petition, EAIC initiated a Petition for Annulment of Judgment based on claims of lack of jurisdiction and fraud. The respondents countered that EAIC was already aware of the ongoing litigation due to the annotations on the title, which they argued constituted constructive notice.
Court of Appeals Decision
The Court of Appeals upheld the RTC's ruling, determining that EAIC had constructive notice of the pending litigation and thus could not claim ignorance. The appellate court maintained that the annotations provided sufficient notice and that EAIC's failure to act constituted a waiver of its right to participate in the proceedings.
Supreme Court Ruling
The Supreme Court reversed the decision of the Court of Appeals, finding that the serv
...continue readingCase Syllabus (G.R. No. 146595)
Case Background
- Title: Ellice Agro-Industrial Corporation, represented by its Chairman of the Board of Directors and President, Raul E. Gala, Petitioner, vs. Rodel T. Young, Delfin Chan, Jim Wee, and Guia G. Domingo, Respondents.
- Court: Supreme Court of the Philippines
- Citation: 699 Phil. 48
- Division: Third Division
- Date: November 21, 2012
- Nature of Petition: Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Lower Court Decisions Challenged:
- July 1, 2003 Decision of the Court of Appeals (CA) dismissing the petition.
- August 8, 2006 Resolution of the CA denying the motion for reconsideration.
Facts of the Case
- On July 24, 1995, the respondents (Rodel T. Young, Delfin Chan, and Jim Wee) entered into a Contract to Sell with Ellice Agro-Industrial Corporation (EAIC) for a 30,000 square-meter parcel of land in Quezon, with a total sale price of P1,050,000.00.
- Respondents made a partial payment of P545,000.00 but EAIC failed to deliver the owner’s duplicate certificate of title and the corresponding deed of sale.
- In response to EAIC's failure to comply, respondents annotated an Affidavit of Adverse Claim on November 8, 1996, on the title of the property.
- Respondents filed a Complaint for specific performance on November 14, 1996, and a Notice of Lis Pendens was annotated on the title shortly thereafter.
- Initial service of summons to EAIC through its representative, Guia G. Domingo, was unsuccessful; however, a second attempt at Domingo’s residence was successful.
- EAIC, represented by Domingo, filed an Answer with Counterclaim on March 21, 1997.
- Respondent Jim Wee communicated with EAIC's Chairman, Raul E. Gala, regarding the execution of a deed of sale in mid-1997, but EAIC