Case Summary (G.R. No. 144294)
Facts
Following a Special Power of Attorney allowing Narcisa Chanliongco to act on behalf of herself and other co-owners, her daughter Adoracion C. Mendoza sold the subject property to the respondents in September 1986. Conflicts arose among the heirs regarding the sale's legitimacy, prompting the respondents to file a Complaint for interpleader in the Regional Trial Court (RTC) to ascertain rightful ownership. The RTC initially supported the sale concerning Narcisa’s shares but ruled that Adoracion did not hold authority to sell the shares of other co-owners. The Court of Appeals (CA), however, reversed this ruling, asserting that Adoracion was authorized as a sub-agent and upholding the sale. This decision became final on August 8, 1996, without an appeal.
Petition for Review
On April 10, 1999, the petitioners filed a Motion to Set Aside the Decision before the CA, arguing that they were not served copies of the Complaint or summons and had not been included as parties to the RTC case. They contended that the CA's decision adversely affected their property interests without due process. The CA denied their Motion, highlighting multiple reasons, including the motion's incompatibility with the 1997 Rules of Civil Procedure, the final and executory status of the decision, and the petitioners' lack of legal standing.
Issue
The central issue raised in the petition is whether the CA erred in denying the petitioners' Motion to set aside the previous decision despite their claims of lack of jurisdiction and violation of due process in the ownership adjudication process.
Court's Ruling
The Court denied the petitioners’ plea, underscoring the principle that a final decision is immutable and unalterable, with limited exceptions, none of which applied in this case. The Court scrutinized the procedural issues surrounding the service of summons and the necessity of impleading the petitioners. It determined that the interpleader action was in rem, affecting the title to real property rather than personal liabilities. As such, the deceased co-owners, represented by their respective estates, were the proper parties to the action, thereby removing the requirement to include the petitioners.
Jurisdiction and Standing
The ruling clarified that the petitioners, as heirs, had no standing regarding direct participation in the case because their father's estate was already represented. Consequently, the failure to serve summons upon them d
...continue readingCase Syllabus (G.R. No. 144294)
Case Overview
- Jurisdiction: Supreme Court of the Philippines
- Decision Date: March 11, 2003
- Case Number: G.R. No. 144294
- Division: Third Division
- Justice: Panganiban, J.
Parties Involved
- Petitioners:
- Soledad Chanliongco Ramos
- Francisco D. Chanliongco
- Adelberto D. Chanliongco
- Armando D. Chanliongco
- Florencio D. Chanliongco
- Respondents:
- Teresita D. Ramos
- Spouses Teresita and Edmundo S. Muyot
- Spouses Vedasta and Florencio M. Dato
- Loreto Muyot
- Spouses Teresita and Elmer Solis
- Liceria Torres
- Spouses Corazon and Vicente Macatungal
- Spouses Precilla and Crisostomo Muyot
- Spouses Caridad and Salvador Pingol
Background of the Case
- The petitioners are the children of Paulino V. Chanliongco Jr., co-owner of Lot No. 2-G in Tondo, Manila.
- The lot was co-owned with his sister Narcisa and brothers Mario and Antonio.
- A Special Power of Attorney allowed Narcisa’s daughter, Adoracion C. Mendoza, to sell the lot to respondents in September 1986.
- Disputes arose regarding the validity of the sale, prompting respondents to file a Complaint for interpleader with the Regional Trial Court (RTC).
Procedural History
- The RTC ruled the sale valid concerning Narcisa’s share but invalidated it for the other co-owners.
- On appeal, the Court of Appeals (CA) modified the RTC ruling, stating Ado