Title
Estate of Soledad Manig vs. Ladanga
Case
G.R. No. 167284
Decision Date
Jul 6, 2011
The estate of Soledad Maninang sought to annul CA's resolutions refusing to act on motions related to property claims. The SC dismissed the petition, affirming no grave abuse of discretion by the CA.
estate
probate
conveyance

Case Summary (G.R. No. 167284)

Procedural History and Material Antecedents

In 1975, Clemencia, during her lifetime, through her adopted son and judicially-appointed guardian Bernardo, filed a reconveyance case before Branch 93 of the Regional Trial Court of Quezon City against spouses Ladanga. The complaint sought to annul two sales allegedly executed by Clemencia in favor of spouses Ladanga involving the Diliman and Cubao properties, based on alleged lack of intent to convey and lack of consideration. In 1977, Clemencia died while the reconveyance case was still pending, and Bernardo was substituted as plaintiff by reason of his status as a known putative heir.

Clemencia’s death also triggered estate settlement proceedings (the Probate Case) between Maninang (represented by QT) and Bernardo. Maninang claimed Clemencia bequeathed to her the entire estate under a will. Bernardo countered that the will was void due to preterition. The Probate Case was ultimately resolved through a compromise agreement executed by Bernardo, Maninang, and their respective counsels, which identified certain estate properties and provided for their distribution. For properties not specifically identified, the compromise agreement provided that Maninang would receive a thirty-five percent interest and QT would receive a fifteen percent interest under the clause covering “any other real properties, known or unknown.”

From the Probate compromise and its November 5, 1992 Decision based thereon, the relevant distribution included a provision for “any other real properties, known or unknown,” giving allocations among Aseneta’s side, Maninang, and QT, with the compromise defining QT’s share as a fifteen percent interest and Maninang’s as thirty-five percent, while other portions were attributed to Bernardo and his counsel ALGR (as stated in the excerpted terms).

The Reconveyance Case, the Cubao Issue, and the CA Decision

As early as 1987, while the Probate Case was still pending, Bernardo alleged that a development occurred in the reconveyance case: Bernardo and spouses Ladanga allegedly entered into another compromise concerning the Cubao property, including an agreement to sell the Cubao property to an unmentioned third party. The record did not include a copy of the alleged compromise agreement, nor the details of consideration or payment.

After approximately two decades in the trial court, the reconveyance case was decided on February 24, 1995, ordering spouses Ladanga to reconvey both the Diliman property and the Cubao property to Bernardo “for and in behalf of Miss Clemencia Aseneta.” The trial court also ordered an accounting of rentals, payment of attorney’s fees, and costs, as reflected in the dispositive portion.

Spouses Ladanga appealed the trial court’s reconveyance judgment to the CA, and the appeal was docketed as CA-G.R. CV No. 51242. At the appellate stage, petitioners—being the Estate of Maninang and QT—attempted to join Bernardo as appellee by filing a Motion for Joinder of Additional Parties on September 2, 1996. Petitioners asserted that the Probate Case had already granted them a fifty percent undivided interest in the Cubao property, which they argued should be included under the compromise’s clause for “any other property, known or unknown.” Bernardo opposed joinder on the ground that the spouses Ladanga’s appeal involved only the Diliman property and not the Cubao property. Spouses Ladanga did not dispute Bernardo’s point as to what the appeal covered; they opposed joinder instead by arguing that petitioners’ claimed right to a share in Clemencia’s estate was dubitably established and should be threshed out in appropriate proceedings.

Without resolving the joinder motion, the CA, in its November 7, 2000 Decision, affirmed the trial court in toto insofar as it related to the Diliman property. Bernardo and petitioners’ dispute over the Cubao property remained unresolved at that stage as to petitioners’ participation.

Appeal to the Supreme Court and Petitioners’ Later Motions

On November 24, 2000, spouses Ladanga appealed the CA Decision to the Supreme Court in G.R. No. 145874. The Supreme Court later affirmed the CA Decision concerning the Diliman property in a September 30, 2005 Decision that became final on November 11, 2005. The Supreme Court thus definitively resolved that the appellate controversy in CA-G.R. CV No. 51242 related to the Diliman property and did not concern the Cubao property.

Meanwhile, in 2001, petitioners learned of the CA Decision in CA-G.R. CV No. 51242. Petitioners filed before the CA a Motion for Partial Reconsideration of the November 7, 2000 Decision. They sought nullification or reconsideration of the compromise agreement between Bernardo and spouses Ladanga concerning the Cubao property, contending that Bernardo lacked authority from the probate court to enter into such a compromise, or alternatively that no such compromise existed. They did not frame their reconsideration as relating to the Diliman property, but to the Cubao property and the compromise allegedly affecting it.

In a June 1, 2004 Resolution, the CA refused to act on petitioners’ Motion for Partial Reconsideration. It grounded its refusal on the pendency before the Supreme Court of the spouses Ladanga’s petition for review in G.R. No. 145874. When petitioners sought reconsideration of that June 1, 2004 Resolution, the CA, in a December 29, 2004 Resolution, denied the motion and reiterated that prudence and judicial decorum required deferring action until the Supreme Court finally resolved G.R. No. 145874.

Issues Presented

The case presented whether petitioners had a right to have their claims adjudicated with respect to the Cubao property in the appeal in the reconveyance case such that the CA’s refusal to act on their motions constituted grave abuse of discretion amounting to lack or excess of jurisdiction, or whether the CA acted within permissible limits by declining to entertain those motions at that stage.

Arguments of Petitioners and Respondents

Petitioners argued that the CA erred in declining to act based on the pendency of spouses Ladanga’s Supreme Court petition. They maintained that the Supreme Court case involved only the Diliman property, while their Motion for Partial Reconsideration sought a ruling on matters relating to the Cubao property and the alleged compromise affecting it. They contended that the difference in subject matter prevented any risk of conflicting rulings. Petitioners further invoked Section 8 of Rule 42 of the Rules of Court, asserting that the CA retained jurisdiction to act on their motions because they filed within the time to appeal of the other parties when they moved for partial reconsideration. As to their Motion for Joinder of Additional Parties, petitioners asserted that the CA had a ministerial duty to act, grounded on constitutional principles, and they emphasized their claimed status as pro indiviso co-owners of the Cubao property by virtue of the Probate Case.

Bernardo took the position, among others, that he waived the filing of a comment and submitted the petition for resolution, while spouses Ladanga argued that the CA acted correctly because it had already lost jurisdiction over CA-G.R. CV No. 51242 after the Supreme Court took cognizance of the appeal. They also argued that memoranda were waived due to the circumstances described in the records.

The Court’s Ruling on the Merits

The Court dismissed the petition for lack of merit. It held that petitioners’ motion to join and participate in the appeal became moot because the Cubao property had already been adjudicated in favor of Clemencia’s estate with finality by the trial court’s February 24, 1995 reconveyance judgment. The Court noted that spouses Ladanga had appealed only the order to reconvey the Diliman property, and that the Supreme Court’s later ruling in G.R. No. 145874 finally determined that the CA appeal under CA-G.R. CV No. 51242 involved only the Diliman property. With respect to the Cubao property, it was already settled with finality that it should be reconveyed by spouses Ladanga to Clemencia’s estate.

The Court further reasoned that the CA did not gravely abuse its discretion in refusing to allow petitioners to join and participate in the appeal of the reconveyance case. While the Court recognized that the CA’s approach “may not have been ideal,” it concluded that the CA’s actions did not amount to grave abuse of discretion. The Court underscored that the issues petitioners raised did not relate to the subject matter before the CA—petitioners’ interest concerned the Cubao property, but the appeal before the CA concerned the Diliman property.

The Court also treated petitioners’ ultimate objective—obtaining an alleged share in the Cubao property—as something that could not be litigated within the appeal of the reconveyance case. That objective required a separate and distinct suit or proceeding. The Court characterized petitioners’ cause of action as independent of the cause of action in the reconveyance appeal. The Court emphasized that resolving petitioners’ claims during the appellate stage would produce undue delay and prejudice, given that respondents had already endured more than two decades to resolve the reconveyance issues.

Finally, the Court stated that petitioners’ claims presented contentious matters—such as the scope of the Probate compromise agreement as it might apply to the Cubao property, the authority of Bernardo to compromise estate property in the reconveyance proceedings, and other defenses involving other in

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