Title
Reburiano vs. De Vera
Case
G.R. No. 243896
Decision Date
Jul 15, 2020
Land sale rescission led to unlawful detainer; MTC's void judgment annulled, property returned to original owner after auction sale deemed null.
ejectment case
annulment of sale
return of property
A

Case Summary (G.R. No. L-68056)

Petitioner’s Transactional Background and Rescission Agreement

  • Reburiano and her husband sold the property to Ruth for US$60,000 payable in installments over three years from July 1, 2000. By November 9, 2003, Ruth had paid US$29,935.00.
  • On January 17, 2004, the parties agreed to rescind the sale due to Ruth’s failure to complete payment. Under the rescission agreement, Reburiano agreed to refund US$20,000 to Ruth (US$12,500 down, balance payable monthly) and Ruth agreed to vacate the property upon tender of the down payment. Reburiano tendered US$12,000 but Ruth and Jojit did not vacate.

MTC Proceedings, Judgment, and Implementation Attempts

  • Reburiano filed an unlawful detainer action against Jojit before the MTC (Civil Case No. 880-AF(04)). The MTC’s Amended Decision dated July 27, 2006 ordered: (a) defendant to vacate and restore possession; (b) defendant to pay reasonable compensation for use and occupation at P10,000.00 per month from January 17, 2004 until vacatur; (c) attorney’s fees of P25,000.00; (d) costs; and (e) ordering plaintiff to pay Ruth and/or defendant by way of refund US$20,000 less the total sum cumulatively due plaintiff as reasonable compensation for defendant’s use and occupancy. The MTC conditioned eviction on satisfaction of the monetary dispositions.
  • Reburiano deposited US$13,500 with the MTC on August 30, 2006 (US$6,500 short of US$20,000), asserting deduction for reasonable compensation. A writ of execution issued September 5, 2008. Sheriff Palmares demanded compliance and computed amounts in pesos, then annotated a notice of levy on TCT No. 540832 (November 6, 2008).

Sheriff’s Sale and Resulting Title Annotation

  • On May 15, 2009, Sheriff Palmares conducted a public auction of the levied property. Jojit was declared highest bidder at US$20,000; no cash changed hands because the sheriff treated the alleged US$20,000 judgment debt as consideration. The Certificate of Sale was approved and annotated on the title on June 8, 2009; a Final Certificate of Sale was issued on June 10, 2010. An ex parte motion to cancel the TCT annotation filed by Augustus was denied by the MTC.

Civil Action for Quieting of Title and Lower Court Rulings

  • Reburiano (by attorney-in-fact) filed a Complaint for Quieting of Title with Damages in the RTC (Civil Case No. 09-8948), seeking annulment of the levy, cancellation of the certificate of sale and title annotation, and damages. She asserted efforts to comply with the MTC judgment and alleged the judicial deposit was refused, and that the auction and sale were unlawful.
  • Jojit countered that Reburiano failed to return the US$20,000 as ordered and therefore forfeited rights to the property; he maintained the levy and sale were valid.
  • The RTC dismissed the quieting complaint on January 27, 2016, reasoning that Reburiano no longer had legal or equitable title because she failed to redeem the foreclosed property within the one-year period and did not timely challenge the validity of the levy and certificate of sale.

Court of Appeals Decision and Petition to the Supreme Court

  • The CA, in a decision dated July 13, 2018, affirmed the RTC. The CA noted Reburiano did not appeal the MTC decision, did not tender payment after demand, delayed claims and judicial deposit for years after the MTC decision and after the auction, and that the demand letter contained a specific computation. The CA concluded Reburiano failed to exercise her right to redeem within one year and that Jojit became the absolute owner. The CA denied reconsideration on November 23, 2018.
  • Reburiano elevated the matter to the Supreme Court via a Petition for Review on Certiorari under Rule 45, raising as her principal contention that the execution and sale were void to the extent they enforced a monetary award beyond what an ejectment action may properly order—specifically that the MTC ordered restitution in the amount of US$20,000 which was not among permissible Rule 70, Section 17 reliefs.

Legal Issue Framed by the Supreme Court

  • The Supreme Court framed the issue as whether an MTC judgment in an ejectment case that enforces the rescission of a purchase agreement by awarding the sum of US$20,000 less reasonable compensation is partially void for not being among the permissible reliefs in an ejectment case under Section 17, Rule 70 of the Rules of Court.

Applicable Law and Doctrinal Standards Applied (1987 Constitution Relevant)

  • Constitutional framework: 1987 Philippine Constitution governs cases decided in 1990 or later (the present decision falls under that framework).
  • Rules of Court cited: Rule 70, Section 17 (enumerates permissible reliefs in ejectment actions: restitution of premises; arrears of rent or reasonable compensation for occupation; attorney’s fees; costs); Rule 51, Section 8 (errors not assigned will not be considered unless affecting jurisdiction or closely related); Rule 47, Section 2 (grounds for annulment of judgment such as extrinsic fraud, lack of jurisdiction, denial of due process).
  • Civil Code Article 22 (unjust enrichment) was applied in resolving restitution between parties where property and payments were involved.
  • Doctrines cited: courts may consider unassigned errors where necessary for a just resolution; void judgments for lack of jurisdiction are nullities and cannot be the basis for execution or res judicata.

Supreme Court’s Analysis on Jurisdictional Limits of an MTC in Ejectment Cases

  • The Court emphasized that Section 17, Rule 70 limits the monetary reliefs available in ejectment cases to those related to possession and use (reasonable compensation for occupation, arrears of rent), attorney’s fees and costs; it does not authorize an MTC, in an ejectment proceeding, to adjudicate or implement restitution of money arising from the rescission of a sale contract.
  • The Court relied on the established principle that damages in ejectment are limited to losses incurred by the plaintiff as mere possessor (loss of use and occupation) and that other monetary claims (e.g., restitution of purchase price) fall outside the scope of ejectment proceedings and are properly the subject of ordinary actions. The MTC’s order to return US$20,000 was therefore beyond the permissible reliefs and was characterized as exceeding the court’s jurisdiction over the matter resolved in the ejectment case.

Court’s Determination of Partial Voidness and Consequences

  • The Supreme Court held that the fifth instruction of the MTC (ordering plaintiff to refund US$20,000 less reasonable compensation) was beyond the MTC’s jurisdiction and was a nullity. Because that part of the Amended Decision was void for lack of jurisdiction, the writ of execution, notice of levy, and certificate of sale that stemmed from and enforced that portion of the judgment were likewise partially void to the extent they implemented rescission by awarding the US$20,000.
  • The Court noted that although the parties did not assign this specific error, the resolution of this jurisdictional issue was indispensable to the just determination of the parties’ rights; hence the Court exercised its discretion to consider and correct the unassigned but jurisdictional error.

Reliefs Ordered by the Supreme Court and Implementation

  • The Supreme Court set aside the CA decision and resolution. It declared the MTC Amended Decision of July 27, 2006 partially null and void insofar as it ordered restitution of US$20,000 less occupancy compensation.
  • The writ of execution, notice of levy upon judgment, and certificate of sale annotated on TCT No. 540832 were declared null and void. The Register of Deeds of Rizal was ordered to cancel the annotation of the notice of levy and the certificate of sale on the title.
  • In the interest of judicial economy and to avoid multiplicity of actions, the Court treated Reburiano’s RTC quieting suit as a petition for annulment of judgment under Rule 47 and proceeded to adjudicate rights on the record. Applying the principle of unjust enrichment (Article 22), the Court held that the US$20,000 that Reburiano had received from Ruth as down payment should be returned in exchange for the subject property. Th

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