Case Summary (G.R. No. 175123)
Complaint Background
Respondents filed their Complaint against the petitioners on August 4, 1998, asserting that they were the rightful owners of the disputed lots, Lot No. 2346 and Lot No. 2527, which were originally covered by Original Certificates of Title (OCT) Nos. 3322 and 3323. They claimed the titles were transferred to Moldex through allegedly falsified Deeds of Absolute Sale executed on May 21, 1996, despite the deaths of their parents, Rafael and Ursula Villabona, before this execution could have occurred.
Petitioner’s Defense
In their Answer, petitioners denied the allegations, with Agero claiming he was not an agent of Moldex Realty and Moldex asserting that it purchased the lots after being offered by real estate brokers, Sayo and Agero. Moldex contended that a valid agreement was made, and payments were issued, including check endorsements by respondent Ricardo.
Procedural History and RTC Proceedings
The trial commenced, but subsequent hearings faced numerous postponements due to the absence of respondents and their counsel. By January 18, 2001, the Regional Trial Court (RTC) declared the presentation of evidence by respondents closed due to their non-appearance. Several motions and requests for rescheduling occurred, highlighting the chaotic and drawn-out nature of the proceedings influenced by absences from respondents.
RTC Decision
Ultimately, on January 28, 2002, the RTC dismissed the case by ruling that the TCTs in favor of Moldex Realty were null and void, ordering the petitioners to pay damages and attorney’s fees to the respondents. This decision was allegedly made despite the ongoing procedural issues regarding the evidence presentation.
Motion for Reconsideration
Petitioner Moldex filed a Motion for Reconsideration arguing that the RTC erred in rendering its decision before allowing them to present their defenses and evidence. They contended that they had been deprived of due process as the trial court had not resolved their concerns regarding the premature closure of the evidence presentation.
Court of Appeals Ruling
The Court of Appeals affirmed the RTC’s ruling, asserting that petitioners had sufficient opportunity to present their evidence and emphasized the conclusions drawn based on documents submitted with the Complaint. They ruled that the Deeds of Absolute Sale presented by the petitioners were invalid.
Supreme Court Findings
The Supreme Court found significant procedural errors by the RTC, highlighting that petitioners were not allowed to pres
...continue readingCase Syllabus (G.R. No. 175123)
Case Overview
- Case Citation: 690 Phil. 193
- Date of Decision: July 04, 2012
- Petitioners: Moldez Realty Inc. and Anselmo Agero
- Respondents: Spouses Ricardo J. Villabona, Gilda G. Villabona, and Eduardo J. Villabona
- Court: Supreme Court of the Philippines, Second Division
- Nature of Petition: Petition for Review under Rule 45 of the Rules of Court
Facts of the Case
- Respondents filed a complaint on August 4, 1998, seeking the annulment of Transfer Certificate of Title (TCT) Nos. NT-250333 and NT-250334, originally covered by Original Certificate of Title (OCT) Nos. 3322 and 3323.
- Respondents claimed ownership of Lot No. 2346 and Lot No. 2527, acquired through a Deed of Sale from their parents in 1977.
- Allegations surfaced that Moldex Realty, Inc., through its representative Levi P. Sayo, fraudulently acquired the titles by encashing checks and executing falsified Deeds of Absolute Sale after the death of the original owners.
- Petitioners denied the allegations and asserted that the respondents willingly sold the properties and handed over the titles.
Procedural History
- The case underwent trial, with significant delays attributed to the absence of respondents and their counsel during scheduled hearings.
- The Regional Trial Court (RTC) issued orders regarding the closure of