Title
Eternal Gardens Memorial Park Corp. vs. Court of Appeals
Case
G.R. No. 123698
Decision Date
Aug 5, 1998
A transferee pendente lite is bound by a final judgment annulling a title, despite pending unrelated litigation, ensuring execution of rightful ownership.

Case Summary (G.R. No. 181571)

Background of the Case

On May 18, 1981, respondents Jose Seelin and Lilia Sevilla filed a complaint against Central Dyeing for quieting of title and nullification of Transfer Certificate of Title No. 205942 in Caloocan City, leading to Civil Case No. C-9297. The trial court's judgment on August 24, 1989, declared Central Dyeing's title null and void and was subsequently affirmed by the Court of Appeals and the Supreme Court, rendering the decision final on March 5, 1992. After the respondents moved for the execution of the judgment, the trial court issued a writ of execution.

Petitioner’s Claims and Oppositions

Eternal Gardens Memorial Park Corporation contested the execution, asserting that it was a bona fide purchaser of the land from Central Dyeing and denied jurisdiction of the trial court; thus, claiming a lack of involvement in the previous case. The trial court and subsequently the Court of Appeals dismissed these assertions, emphasizing that the petitioner is bound by the earlier decisions given their acknowledged acquisition of the property from the defendant in Civil Case No. C-9297.

Further Legal Maneuvers

Following various motions and petitions filed by the petitioner, including a futile petition for certiorari with the Court of Appeals and further appeals to the Supreme Court that were affirmatively dismissed, the execution process continued. The petitioner alleged that execution should be delayed due to ongoing legal issues, including a separate Civil Case No. C-11337 that sought nullification of multiple titles, including those of the respondents.

Court’s Rationale on Execution

The courts upheld that execution of the judgment from Civil Case No. C-9297 could not be postponed based on the pendency of later actions. The judgment against the original title had long since been finalized, thereby res judicata applied, and neither the existence of subsequent cases nor the potential safety of burial lot owners altered the enforceability of the judgment.

Final Observations on Judicial Function

After reiterating that the legal process had been unduly delayed, which adversely affected the rightful owners, the court firmly reminded that attorneys, while advocating for their clients, should aim to assist in justice rather than further complicate matters. The court's decision highlighted t

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