Case Summary (A.C. No. 5279)
Factual Background
Marciano A. Roxas died intestate in 1950, leaving behind a widow and children. In 1955, his heirs filed a specific performance action against the heirs of Gregorio Galindo, seeking to compel the execution of a deed of sale concerning Lot 1048. The case revealed that Lot 1048 was originally subject to a sale agreement between the government and Gregorio Galindo, later transferred to Marciano A. Roxas, but not officially registered due to Urbano Galindo's minority at the time of the transaction.
Court Decisions and Proceedings
On August 12, 1965, the trial court ruled in favor of Marciano Roxas' heirs, ordering the defendants to execute a deed of sale for Lot 1048. The Court of Appeals affirmed this decision in 1973, but enforcement of the ruling lagged due to bureaucratic inaction. The Lot was subsequently transferred to Juanita Galindo Rivera after the extrajudicial settlement executed by Urbano Galindo's heirs in 1997.
Legal Actions Post-Settlement
In April 1999, the Roxas heirs filed a complaint against Juanita Galindo Rivera in the Regional Trial Court of Bulacan, seeking annulment of the extrajudicial settlement and cancellation of the title TCT No. 335593(M). They claimed this settlement contradicted the prior ruling affirming their ownership of Lot 1048.
Motion to Dismiss and Court's Rulings
Juanita Galindo Rivera filed a motion to dismiss, arguing the Roxas heirs lacked legal capacity to sue and that their cause of action had prescribed. The trial court denied this motion, finding the plaintiffs had the capacity to sue as they were legitimate heirs of Marciano Roxas. The trial court classified the complaint under "quieting of title" principles rather than mere enforcement of the earlier decision.
Appellate Review and Findings
The Court of Appeals dismissed the petition for certiorari against the trial court's orders, upholding that the trial court's actions were not marked by grave abuse of discretion. However, the case was escalated to higher courts for further resolution.
Legal Capacity and Indispensable Parties
The Supreme Court evaluated whether all petitioners were proper parties in the case. It found that since some petitioners were not part of the earlier trial, they could not challenge the orders issued. Nevertheless, it recognized them as indispensable parties necessary for a valid court ruling. Their absence rendered the trial court's decisions null regarding their interests in the property.
Jurisdictional and Procedural Points
The Court underscored the
...continue readingCase Syllabus (A.C. No. 5279)
Case Background
- The case revolves around the intestate succession of Marciano A. Roxas, who passed away on June 4, 1950, leaving behind a widow, Cirila Roxas, and nine children.
- The heirs of Marciano A. Roxas, represented by Reginald S. Roxas, filed an action for specific performance against the heirs of Gregorio Galindo, aiming to compel them to execute a deed of absolute sale for Lot 1048 in Sta. Maria, Bulacan.
- Lot 1048, covering 48,089 square meters, was initially possessed by Gregorio Galindo, who had been paying rent for the lot to the government.
Key Facts of the Case
- Gregorio Galindo entered into an agreement with the Philippine government on July 5, 1911, to purchase Lot 1048 for P859.50, payable in annual installments.
- Following Galindo's intestate death in 1916, his heirs sold their rights to Lot 1048 to Marciano A. Roxas, although Urbano Galindo, a minor at the time, did not sign the sale document.
- The heirs obligated themselves to transfer the land to Roxas once feasible and provided security by ceding title to another lot (Lot 833) to ensure Urbano's future ratification of the sale.
- Urbano Galindo ratified the sale in 1931 upon reaching adulthood.
- Although Roxas made payments and paid real estate taxes on Lot 1048, the title was issued in the name of Gregorio Galindo’s heirs due to the sale not being registered because of Urbano's minority.
Trial Court Proceedings
- The trial court ruled in favor of the heirs of Marciano Roxas on August 12, 196