Case Summary (G.R. No. 57757)
Background of the Case
On October 7, 1974, the petitioners filed an action for annulment of the sale of their property made by their daughter Trinidad Estoesta to Villamor. They claimed ownership rights as the initial awardees of the property from PHHC in 1953, detailing that they later transferred it into Trinidad's name for convenience while remaining the true owners. The petitioners asserted that the subsequent sale to Villamor contravened a five-year prohibition against such transfers without PHHC's consent.
Proceedings and Decision of Lower Courts
The trial court, after hearing the case on August 15, 1978, ruled in favor of the petitioners. It declared the sale to Villamor as void, ordered the cancellation of the titles involved, and instructed the issuance of a new title in favor of the petitioners. However, Villamor's subsequent motions for reconsideration, filed beyond the reglementary period, were acknowledged by the court leading to an appeal. The appellate court, in a decision dated October 30, 1984, reversed the trial court's ruling, validating the sale to Villamor and ordering the petitioners to vacate the property and pay damages.
Execution of Judgment
Following the appellate court's ruling, a writ of execution was issued to enforce the decision, prompting the petitioners to file an urgent motion to quash the writ. Their motion was denied on May 21, 1986, as was their motion for reconsideration on May 29, 1986. This led to the filing of the present petition for certiorari, prohibition, and mandamus.
Legal Issues Raised
The petitioners argued that the trial court acted with grave abuse of discretion by enforcing the writ of execution concerning a judgment they claimed was a patent nullity, asserting that the appeal by Villamor was not perfected within the time frame prescribed by law and thus the trial court's judgment had long become final and executory.
Analysis of Timeliness of Appeals
The Court noted that the crucial issue was the timeliness of the appeal filed by Luis Villamor. It was established that Villamor's counsel received a copy of the trial decision on September 5, 1978, and that the appeal was only initiated on August 7, 1979, well beyond the reglementary period. The Court held that the non-perfection of the appeal rendered the trial court's ruling final and executory, depriving the appellate court of jurisdiction to alter the decision.
Interpretation of Finality of Judgments
The ruling emphasized that the perfection of an appeal within the specified reglementary period is mandatory and jurisdictional. The Court reiterated that if an appeal
...continue readingCase Syllabus (G.R. No. 57757)
Case Background
- Petitioners: Simeon Estoesta, Sr. and Lucia Estoesta
- Respondents: Court of Appeals, Hon. Eduardo C. Tutaaan, Quezon City Sheriff and his Deputy Sheriff Juanito B. Lindo, Trinidad Estoesta, Luis Villamor
- Case Reference: G.R. No. 74817
- Date of Decision: November 08, 1989
- Nature of Petition: Petition for certiorari, prohibition, mandamus with a prayer for a restraining order.
Procedural History
- The petition seeks to annul two Orders dated May 21, 1986, and May 29, 1986, which denied the petitioners' urgent motion to quash a writ of execution.
- The case originated from an action for the annulment of the sale of a property involving petitioners’ daughter and private respondent Luis Villamor.
Factual Antecedents
- Property Details: The subject property is a house and lot located at 54-A Legaspi Street, Project 4, Quezon City, originally awarded to the petitioners by the Philippine Homesite and Housing Corporation (PHHC) in 1953.
- Transfer of Property: In 1967, the petitioners moved to Davao, leaving their daughter Trinidad Estoesta in charge of the property. They later transferred rights to Trinidad for convenience in dealings with PHHC.
- Deed of Sale: Trinidad Estoesta sold the property to Luis Villamor on August 5, 1974, without PHHC's consent, despite a five-year restriction on sales.
- Legal Action Initiated: Petitioners filed a suit seeking cancellation of the sale to Villamor, asserting that the sale was void due to lack of consent and that Villamor