Case Summary (G.R. No. 229701)
Factual Background
The late Francisco Guballa, Sr. was the registered owner of a parcel of land in Quiapo, Manila, identified under Transfer Certificate of Title No. 15638, including improvements known as the Bulaklak Building. Following the suspension of his business operations, a labor union known as BUSCOPE filed a complaint for unpaid separation pay, leading to the property’s auction sale in favor of BUSCOPE. Subsequently, Judge Amado G. Inciong ruled in favor of Guballa Sr., restoring ownership of the property. The legal complications were further exacerbated by various transactions and litigations regarding the property, including sales to Atty. Rufino Risma and a subsequent lease agreement with Emeterio M. Mozar.
Writ of Possession Case (G.R. No. 78223)
Following the Labor Union's auction and Guballa Sr.’s restoration of ownership, the Risma spouses sought a writ of possession, which the Court of First Instance granted. Guballa’s appeal against this decision was dismissed by the Court of Appeals for failure to comply with a substitution order following the transfer of the property to Guballa Marketing Corporation. The dismissal was primarily based on the court’s view that the original parties must include the current owner, failing which the appeal was dismissed as a result of non-compliance with procedural orders.
Ejectment Case (G.R. No. 79403)
Simultaneously, a separate ejectment case was initiated by Guballa Sr. against Mozar for unlawful detainment of the property following the expiration of their lease. The trial court and later the Court of Appeals upheld Guballa Sr.’s position, ordering Mozar’s eviction. After various appeals, the execution of the decision was postponed by the Regional Trial Court on the basis of a pending writ of possession and the court's perceived changes in circumstance.
Legal Issues and Rulings
Writ of Possession Case: The Supreme Court reversed the dismissal of the appeal, reinforcing that the need for formal substitution of parties did not warrant such dismissal. The court emphasized that a transferee pendente lite could proceed in the case without mandatory substitution and that technicalities should not derail substantial justice.
Ejectment Case: The High Court affirmed that the execution of the final judgment regarding possession could not be hindered by ongoing property disputes related to title, di
...continue readingCase Syllabus (G.R. No. 229701)
Case Background
- This case involves two petitions for review on certiorari from the decisions of the Court of Appeals regarding G.R. Nos. 78223 and 79403.
- G.R. No. 78223 concerns the appeal dismissal for failure to comply with a lawful order, while G.R. No. 79403 involves a decision affirming the denial of a petition for certiorari and prohibition against Judge Ernesto A. Madamba and others.
Undisputed Facts
- The late Francisco Guballa, Sr. was the registered owner of a parcel of land located at 1002-1004 R. Hidalgo St., Quiapo, Manila.
- The property, under TCT No. 15638, included a building known as the Bulaklak Building, which housed Bulaklak Publications, a business operated by Guballa Sr.
- Following the cessation of business operations, BUSCOPE Labor Union filed a complaint for non-payment of separation pay against Bulaklak Publications and Guballa Sr., leading to a decision in favor of BUSCOPE.
- A writ of execution was issued, resulting in the property being sold at a public auction to BUSCOPE, with the subsequent issuance of a certificate of sale.
Key Transactions
- Sale to Atty. Rufino Risma: On March 10, 1978, BUSCOPE's president sold the property to Atty. Risma without annotating his rights on TCT No. 15638.
- Lease Agreement: On March 31, 1978, Risma entered into a lease agreement with Emet