Case Summary (G.R. No. 169858)
Factual Background
The case involves a dispute over a parcel of land in Balagtas, Bulacan, originally owned by the petitioners, who transferred ownership to their brother Carlito Geronimo for the purpose of developing a resort. The petitioners were motivated by the absence of resort facilities in the area and entrusted their brother with the management of the property. Despite the transfer of ownership, no monetary compensation was provided to the petitioners, and Carlito operated the property as the project manager. He later secured a loan against the property to fund its development into Villa Cristina Resort, jointly managing it with another individual until his death on June 13, 2002.
Petition for Cancellation of Title
Following Carlito's death, the petitioners sought to cancel the property title held by the respondents, who are Carlito's heirs, under the premise that an implied trust had been created and subsequently extinguished upon his death. The petitioners filed this suit in the RTC of Malolos, asserting claims based on the nature of the property transfer and management.
Service of Summons and Jurisdictional Issues
Challenges arose regarding the proper service of summons to the respondents, who contended that the court lacked jurisdiction over their persons by arguing that they were not residing at the address listed in the summons. The RTC initially ordered the issuance of an alias writ of summons due to difficulties in locating the respondents at their claimed address. Respondents, apparently misinformed about their own residence, eventually received the summons and subsequently filed for extensions to respond, which were granted by the court on multiple occasions.
Motion to Dismiss and Default Judgment
The respondents attempted to dismiss the case by arguing improper service of summons and that the petitioners had no cause of action. However, due to procedural issues and the RTC's failure to receive their motion before the deadline for responding, the court declared the respondents in default. Consequently, the RTC allowed the petitioners to present evidence ex parte, leading to a decision nullifying the sale of the property to Carlito.
Court of Appeals Ruling
Dissatisfied with the RTC's decisions, respondents sought recourse in the CA, claiming that the RTC had erred in declaring them in default and issuing its decision without proper jurisdiction. The CA agreed, stating that the RTC had exercised grave abuse of discretion and remanded the case for further proceedings.
Supreme Court's Analysis
On further appeal, the Supreme Court ruled in favor of the petitioners, holding that the CA erred in granting the petition for certiorari. The decision emphasized that the remedy of certiorari is only available when there is no plain, speedy, and adequate rem
...continue readingCase Syllabus (G.R. No. 169858)
Case Background
- Petitioners: Juanito Geronimo, Antonia Limson, and Linda Geronimo, registered owners of a parcel of land in Balagtas, Bulacan.
- Respondents: Heirs of Carlito Geronimo, represented by Angelito Geronimo.
- Context: In 1989, Carlito Geronimo proposed the development of the land into a resort, which led to the petitioners "selling" the land to him, despite no payment being made.
- Carlito was designated as project manager and later secured a loan using the property as collateral to develop the Villa Cristina Resort.
- Carlito passed away on June 13, 2002.
Legal Proceedings Initiated by Petitioners
- On February 7, 2003, petitioners filed a petition for cancellation of title against the respondents in the Regional Trial Court (RTC) of Malolos, Bulacan, asserting that an implied trust existed which was extinguished upon Carlito's death.
- The RTC attempted to serve summons to the respondents but faced difficulties due to incorrect address information. This led to the issuance of an alias writ of summons.
Service of Summons and Respondents' Actions
- Respondents received the alias writ of summons on September 9, 2003, and immediately sought a 15-day extension to file their answer, which was granted by the RTC.
- Respondents continued to seek additional extensions, which the RTC allowed, demonstrating the court's leniency.
- On October 27, 2003, respondents filed a motio