Case Summary (G.R. No. 205194)
Procedural Background
This petition arises from a complaint for annulment and declaration of nullity of a deed of sale and Transfer Certificate of Title (TCT) No. RT-22372 filed by the respondents against the petitioners in the Regional Trial Court (RTC) of Butuan City. The case, docketed as Civil Case No. 3749, asserts that the respondents are legitimate purchasers of land previously registered in the name of Eleuterio Cuenca and challenges the validity of prior sales which purportedly transferred ownership to Andres Aban.
Claims and Actions Taken
Respondents assert that they acquired land in good faith and paid taxes, while alleging that the Deed of Sale executed by Cuenca in favor of Aban for a small amount was fraudulent due to factors such as Cuenca's illiteracy and the absence of possession by Aban or his heirs. The petitioners counter these allegations by detailing the registered titles and previous legal actions confirming their ownership, notably engaging in a quiet title action which resulted in the issuance of TCT No. RT-22372.
Dismissal and Revival Requests
Following several legal maneuvers, including the respondents’ original complaint being dismissed for non-prosecution in 2002, the petitioners sought to revive this judgment in 2012, arguing that the dismissal conferred them rights of ownership and possession. The RTC, however, concluded that a dismissal for failure to prosecute does not constitute a judgment on the merits, thereby hindering the execution of such a dismissal and affirming the initial Order dismissing the revival request for lack of cause of action.
Court's Rationale and Application of Law
The Supreme Court emphasized the need for procedural due process which necessitates that both parties are provided real opportunity to be heard. The petitioners' persistent failure to comply with court directives led to the presumption of waiver regarding the submission of their timely comment. The procedural failings compounded into a substantive dismissal as the appeal lacked merit.
Res Judicata and Merits of the Case
The Court articulated that while the dismissal on grounds of non-prosecution was indeed a judgment, it precluded the refiling of identical claims by respondents, thereby rendering their claims
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Case Information
- Citation: 870 Phil. 596
- Division: Second Division
- G.R. No.: 205194
- Date: February 12, 2020
- Petitioners: Atty. Felino M. Ganal, Manuel G. Aban, Aida Aban, Milagros Aban-Jalop, the heirs of Andres G. Aban, Jr., and the heirs of Anita Aban-Almazora.
- Respondents: Andres Alpuerto, Rico Roquitte, Rosalinda Gaballo, and Leonila Palala, as officers of the Bayanihan Homeowners Association.
Procedural History
- Petitioners filed a Petition for Review on Certiorari under Rule 45, challenging the Orders dated September 26, 2012, and December 5, 2012, issued by Branch 2 of the Regional Trial Court (RTC) of Butuan City. The RTC dismissed their complaint and denied their motion for reconsideration.
- The complaint sought to annul the Deed of Sale and Transfer Certificate of Title (TCT) No. RT-22372 and included claims for damages and a restraining order.
Antecedents
- Respondents filed a complaint for annulment against petitioners, the City of Butuan, and the Register of Deeds, alleging that their members were purchasers in good faith of portions of Lot 427, originally registered under Original Certificate of Title (OCT) No. RO-156.
- Allegations included claims of possession, construction of durable houses, and payment of realty taxes by respondents.
- Respondents contended that the Deed of Sale executed by Eleuterio Cuenca in favor of Andres Aban in 1941 was null and void due to Cuenca's illiteracy and lack of possession by Aban or his heirs.
Petitioners' Response
- Petit