Case Summary (G.R. No. 139672)
Factual Background
The events that led to this litigation can be traced back to a decision rendered on March 29, 1950, by the then Court of First Instance of Rizal, which ruled that the Gonzales or Maysilo Estate in Malabon, with an area of 871,982 square meters, would be expropriated by the Republic of the Philippines, with the understanding that the government would resell the property to its occupants. However, the government failed to implement this decision, which prompted the tenants to file a complaint on October 20, 1960, seeking to compel the People's Homesite and Housing Corporation (PHHC) to sell the lots they occupied.
Legal Action and Orders Issued
On April 29, 1961, GAUF sought to intervene in the case, claiming rights to 507,376 square meters following an agreement with tenants, enabling it to file a compromised agreement later approved by the court. However, this compromise was subsequently declared null and void due to forgery in Civil Cases Nos. 17347 and 17364. Consequently, the RTC issued a joint order on August 29, 1986, declaring any transfer of the lots to GAUF as rescinded and directed the cancellation of GAUF's Transfer Certificate of Title (TCT) No. C-24153, ultimately restoring ownership to the heirs of Gregorio Bajamonde.
Petitioner’s Claims
GAUF contested the RTC's orders by filing a petition for annulment on January 14, 1991, asserting that the trial court lacked jurisdiction to issue the contested orders, arguing that they were a collateral attack on its title, violating Section 48 of Presidential Decree No. 1529, which prohibits collateral attacks on certificates of title. GAUF's main contention hinges on the legality of the trial court's jurisdiction over the case and the corresponding orders.
Appellate Court Findings
The Court of Appeals (CA) upheld the trial court's jurisdiction in its decision dated March 31, 1999, stating that the original case for specific performance actually entailed GAFU’s title validity being litigated within. The CA indicated that GAUF's title stemmed from an agreement that had been declared invalid, thus allowing the RTC to annul the title. It stated that an action to nullify a title is not a direct attack but rather a collateral one when other relief is sought, which ultimately does not absolve the RTC from exercising jurisdiction over the case.
Conclusion of Rulings
The Supreme Court affirmed the CA’s ruling and rejected GAUF’s petition, emphasizing that the court only needed to determine if it possessed jurisdiction over the matter, which it did. It clarified that the petitioner’s title was fundamentally flawed and further indicated that any a
...continue readingCase Syllabus (G.R. No. 139672)
Case Reference
- Citation: 599 Phil. 677
- Date Decided: March 04, 2009
- Court: Supreme Court of the Philippines
- G.R. No.: 139672
- Division: First Division
- Justices: Leonardo-De Castro, Puno, Carpio, Corona, Brion
Parties Involved
- Petitioner: Gregorio Araneta University Foundation (GAUF)
- Respondents:
- Regional Trial Court of Kalookan City, Branch 120
- Register of Deeds of Kalookan City
- National Housing Authority
- Heirs of Gregorio Bajamonde
- Saturnina Mendoza
- Remington Realty Development, Inc.
Background of the Case
- The petition stems from a Decision dated March 31, 1999 by the Court of Appeals (CA) in CA-G.R. SP No. 23872, which upheld previous orders from the RTC of Caloocan City that directed the cancellation of GAUF's Transfer Certificate of Title (TCT) No. C-24153 and the issuance of new titles in favor of the heirs of Gregorio Bajamonde for Lots 54 and 75 of the Gonzales Estate.
- The case's origins trace back to a decision rendered on March 29, 1950, affirming the expropriation of the Gonzales Estate by the Republic of the Philippines, with the intent to resell to its occupants.
Factual Antecedents
- Initial Expropriation: The Gonzales estate, covering 871,982 square meters, was expropriated with the commitment to sell portions to its occupants.
- Legal Proceedings Initiated by Occupants: On October 20, 1960, occupants filed a complaint to compel the government to sell their occupied portions.
- Intervention by GAUF: On April 29, 1961, GAUF intervened, claiming priority rights based on an agreement with 52 tenants for a portion of the estate.
- Compromise Agreement: A compromise was submitted and approved, which included Lots 75 and 54, awar