Case Summary (G.R. No. 109656)
Undisputed Facts
The facts of the case commenced when the defendants failed to honor their contractual obligation to sell a parcel of land to the private respondents. Consequently, on August 25, 1987, the private respondents filed a lawsuit for “specific performance with damages” against the defendants in the Regional Trial Court (RTC) of Bacolod City. A notice of lis pendens was inscribed on the title of the land but was subsequently lifted on November 9, 1988, after the defendants posted a bond. In November 1991, while the case was still pending, the petitioner purchased the lot from the defendants. This prompted the private respondents to amend their complaint to include the petitioner as a defendant, accusing it of being a buyer not acting in good faith.
Legal Proceedings and Challenges
Upon becoming an additional defendant, the petitioner filed a motion to dismiss the amended complaint, arguing two points: the lack of a cause of action and improper venue. The petitioner claimed it was a good faith purchaser because the notice of lis pendens had already been cancelled at the time of purchase. Furthermore, it contended that venue should be at Bago City, where the property is located, rather than Bacolod City. The RTC denied this motion, stating that evidence on the question of good faith was necessary. Petitioner’s motion for reconsideration was also denied.
Petition for Certiorari
Subsequently, on April 21, 1993, the petitioner filed a petition for certiorari under Rule 65, challenging the denial of its motions. The Supreme Court accepted the petition, requiring both parties to submit their memoranda. Notably, after these submissions, the petitioner revealed for the first time that it had sold the lot to Distileria Bago, Inc., with which it had significant stockholdings. The private respondents then moved to dismiss the petition on the basis that the petitioner was no longer a real party in interest.
Ruling on the Petition
The Supreme Court ruled that the petition must be dismissed for several reasons. Firstly, the timeliness of the petition was questioned, as it was filed more than three months after the petitioner received the RTC's resolutions, which is considered an unreasonable delay. It is established that an order denying a motion to dismiss is interlocutory and cannot typically be appealed or challenged via certiorari. The proper remedy for an aggrieved party is to file an answer and assert defenses during the trial, allowing for an appeal only after a final judgment.
Grave Abuse of Discretion
The Court found that the lower court had not abused its discretion in deferring action on the petioner's motion to dismiss, as there were issues regarding the good faith of the petitioner that required factual determination. The standard under Section 3 of Rule 16 permits deferral of such motions until trial if the grounds are not indubitable, and the court reasonably deferred until evidence could be presented.
Venue Considerations
Additionally, regarding the matter of venue, the Court asserted that the nature of the complaint for “specific perform
...continue readingCase Syllabus (G.R. No. 109656)
Case Overview
- The case revolves around a dispute involving a contract for the sale of a parcel of land located in Bago City, which private respondents allege was breached by several defendants, leading to a legal action for specific performance with damages.
- The case is recorded under G.R. No. 109656 and was decided by the Supreme Court of the Philippines on November 21, 1996.
Factual Background
- A group of individuals (defendants) failed to fulfill their contractual obligation to sell a parcel of land to private respondents.
- In response to the breach, private respondents filed a lawsuit on August 25, 1987, in the Regional Trial Court (RTC) of Bacolod City, seeking specific performance along with damages.
- A notice of lis pendens was placed on the title of the property but was later cancelled on November 9, 1988, when the defendants posted a bond.
- In November 1991, while the case was still pending trial, petitioner La Tondeaa Distillers, Inc. purchased the property from the defendants.
- Private respondents amended their complaint to include the petitioner as an additional defendant, claiming that it was not a buyer in good faith.
Legal Proceedings and Motions
- Petitioner filed a motion to dismiss the amended complaint, arguing lack of cause of action and improper venue.
- For the first ground, petitioner contended it was a buyer in good faith since the notice of lis pendens had been cancelled.
- Regarding improper venue, petitioner asserted that the case should be heard in Bago City, where the property