Case Summary (G.R. No. 214934)
Applicable Law
The 1987 Philippine Constitution and the Revised Rules of Court, particularly Section 16, Rule 3 concerning the substitution of parties upon the death of a litigant.
Facts of the Case
The petitioner, Pacific Rehouse Corporation, entered into a Deed of Conditional Sale with Benjamin G. Bautista on February 17, 1994, for a parcel of land in Imus, Cavite, with a total consideration of P7,327,740.00. Despite making substantial payments, Bautista failed to execute the deed of absolute sale and ultimately sold the property to another buyer. Consequently, on April 30, 2008, the petitioner lodged a complaint for specific performance and damages against Bautista. The legal proceedings were interrupted by the death of Bautista on February 14, 2009, which led to procedural challenges regarding the representation of his estate in the pending lawsuit.
Death of the Party and Dismissal
Upon the death of Bautista, the Regional Trial Court (RTC) required the petitioner to substitute his heirs. Initial non-compliance led to the dismissal of Civil Case No. 2031-08. The RTC later reinstated the case but directed the petitioner to secure an appropriate representative. Complications arose when the respondent, Joven L. Ngo, sought the cancellation of the Notice of Lis Pendens, claiming rights over the property under a mortgage agreement he had with Bautista, which culminated in the property being sold at a public auction.
Court of Appeals Ruling
The Court of Appeals (CA) dismissed Civil Case No. 2031-08, ruling that since the underlying obligation was personal to Bautista, the action did not survive his death, thereby invalidating the ongoing complaint. The CA asserted that this dismissal eliminated the basis for the RTC's Omnibus Order that consolidated the civil case and the land registration case, concluding that the consolidation was moot.
Supreme Court Assessment
The Supreme Court found merit in the petition, highlighting that under the relevant rules, the death of Bautista did not extinguish the claim relating to property rights, as established by Section 16, Rule 3 of the Revised Rules of Court. The Court stressed that actions concerning property rights persist despite the death of a party involved. In addressing the nature of the case, the Court estab
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Case Overview
- The case involves a petition for review on certiorari filed by Pacific Rehouse Corporation (petitioner) against Joven L. Ngo (respondent) concerning the dismissal of a complaint for specific performance and damages.
- The case originated from the Court of Appeals (CA) Decision dated March 20, 2014, and Resolution dated October 8, 2014, which set aside the Regional Trial Court (RTC) Orders from April 7, 2011, and September 30, 2011.
Facts of the Case
- On February 17, 1994, petitioner entered into a Deed of Conditional Sale with Benjamin G. Bautista for a parcel of land in Imus, Cavite, for P7,327,740.00.
- The contract stipulated a down payment of P2,198,322.00, with the remainder due upon completion of necessary transfer documents.
- Petitioner paid Bautista P6,598,322.00 but Bautista failed to execute the deed of absolute sale and subsequently sold the property to another party.
- Petitioner filed a complaint for specific performance and damages (Civil Case No. 2031-08) on April 30, 2008, seeking the delivery of the deed of transfer and related documents.
- A Notice of Lis Pendens was annotated on TCT No. T-800 on May 9, 2008, to protect petitioner's rights pending litigation.
- Bautista died on February 14, 2009, leading to complications regarding the substitution of parties in the