Case Summary (G.R. No. 195026)
Factual Antecedents
On May 16, 1969, Gorgonio Medina and other co-owners agreed to partition a parcel of land located in Guimba, Nueva Ecija. Later, on March 29, 1972, Gorgonio Medina sold his 1/3 share of the property to Bonifacio Natividad. Following disputes about ownership, a case for partition with damages was initiated by Tirso Medina in 1989, which culminated in a compromise agreement approved by the Regional Trial Court (RTC) on November 20, 1989.
Compromise Agreement and Subsequent Developments
The compromise agreement adjusted the shares of the co-owners, with various lots being allocated to each co-owner. Lot 1199-C, specifically, was later registered in the name of Gorgonio Medina, who received Transfer Certificate of Title (TCT) No. NT-230248. In 2001, Bonifacio Natividad filed a complaint for annulment of TCT No. NT-230248 and damages, claiming his entitlement to a portion of the land.
Legal Issues Raised
The principal legal issues involved were the authority of Philip M. Natividad to file the complaint on behalf of his father and whether or not the complaint stated a valid cause of action. The petitioners contended that the special power of attorney executed abroad by Bonifacio Natividad and presented by Philip lacked the necessary authentication from a Philippine consular officer, rendering it inadmissible in evidence.
Authority to Sue
The trial court ruled that the special power of attorney, despite lacking consular authentication, was sufficient to grant Philip the authority to represent Bonifacio. However, the Court of Appeals classified the issue surrounding the special power of attorney as a technicality, arguing it should not obstruct substantial justice.
Jurisdictional Considerations
The Supreme Court established that for a special power of attorney executed outside the Philippines to be admissible, it must be authenticated according to Section 25 of the Rules of Court. The absence of such authentication rendered the power of attorney inadmissible, meaning that Philip did not have the authority to file the complaint.
Voiding of Proceedings
The failure to properly authenticate the special power of attorney resulted in the nullification of all proceedings in the lower courts, as they did not have jurisdiction over the real party in interest, Bonifacio Nativi
...continue readingCase Syllabus (G.R. No. 195026)
Background of the Case
- The petitioners, heirs of Gorgonio Medina, filed a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- The case seeks to nullify the Decision of the Court of Appeals dated November 20, 2006, which modified the Decision of the Regional Trial Court (RTC) of Guimba, Nueva Ecija, in Civil Case No. 1165-G, and its Resolution denying the motion for reconsideration.
Factual Antecedents
- On May 16, 1969, co-owners of a parcel of land in Guimba, Nueva Ecija, agreed to divide and allot the land among themselves, which measured 2,339 square meters.
- Gorgonio D. Medina received two portions of the land: one alone and another with co-owners Tirso Medina and Pacifico M. Ruiz.
- On March 29, 1972, Gorgonio D. Medina sold his 1/3 share in one portion of the land to Bonifacio Natividad for P2,000.00.
- A Partition case (Civil Case No. 781-G) was subsequently filed, resulting in a Compromise Agreement approved by the RTC on November 20, 1989, which detailed the allotment of the land among the co-owners.
Compromise Agreement
- The Compromise Agreement recognized co-ownership and detailed the subdivision of Lot 1199 into lots assigned to various parties, including Bonifacio Natividad.
- A supplemental order on October 8, 1991, clarified the areas of the subdivided lots according to the approved partition by a geodetic engineer.
Subsequent Legal Actions
- On June 11, 2001, Bonifacio Natividad