Case Summary (G.R. No. 203241)
Facts
Federico A. Serra is the owner of a 374 square meter parcel of land in Masbate, Philippines. In May 1975, Serra entered into a 25-year Contract of Lease with Option to Buy with RCBC, granting the latter an option to purchase the land within ten years. On September 4, 1984, RCBC attempted to exercise this option; however, Serra informed RCBC that he was no longer interested in selling. This led RCBC to file a Complaint for Specific Performance against Serra in March 1985, initially dismissed but later reinstated by the RTC Makati in January 1989, which ordered Serra to execute a deed of sale. Serra subsequently donated the property to his mother and later it was sold to Liok, triggering further legal disputes.
Legal Background and Proceedings
RCBC sought to nullify the donation and subsequent sale, establishing that they were executed to evade Serra's obligations. The RTC Masbate ruled in favor of RCBC in October 2001, declaring the previous transactions void. The Court of Appeals affirmed this ruling in September 2007, with both Serra and Liok filing separate petitions for review. The Supreme Court ultimately denied these petitions, leading to finality of the decisions.
Execution Issue
On August 25, 2011, RCBC moved for the enforcement of the January 1989 decision, arguing that Serra's fraudulent acts suspended the enforcement period. Serra opposed, claiming the execution motion was barred by prescription and laches. On February 16, 2012, the RTC denied RCBC’s motion, asserting that RCBC failed to register its rights. This denial and subsequent motion for reconsideration were both denied by orders dated July 26, 2012.
Supreme Court Ruling
RCBC's appeal focused on whether the RTC erred in barring execution of the earlier decision. The Court found merit in RCBC's petition, affirming that delays caused by the judgment obligor (Serra) could suspend the enforcement period. The five-yea
...continue readingCase Syllabus (G.R. No. 203241)
The Case
- The petition for review on certiorari is filed by Rizal Commercial Banking Corporation (RCBC) against Federico A. Serra.
- The case challenges orders from the Regional Trial Court (RTC) of Makati City, specifically dated 16 February 2012 and 26 July 2012.
- The petition includes a plea for a Writ of Preliminary Injunction and/or Temporary Restraining Order.
The Facts
- Federico A. Serra is the owner of a 374 square meter parcel of land in Masbate, Philippines.
- On 20 May 1975, Serra and RCBC entered a Contract of Lease with Option to Buy, allowing RCBC to lease the land for 25 years with an option to buy within 10 years.
- On 4 September 1984, RCBC expressed its intent to exercise its option to purchase the property.
- Serra, however, declared he was no longer interested in selling.
- In response, RCBC filed a Complaint for Specific Performance and Damages against Serra in RTC Makati on 14 March 1985.
- Initially dismissed, the RTC Makati reversed its decision on 5 January 1989, ordering Serra to execute the deed of sale.
- Serra appealed to the Court of Appeals (CA).
- While the appeal was pending, Serra donated the property to his mother, Leonida Ablao, on 18 May 1989, and Ablao later sold the property to Hermanito Liok on 20 April 1992, resulting in a new land title.
- RCBC subsequently filed a Complaint for Nullification of Deed of Donation and Deed of Sale with Reconveyance and Damages against Liok, Ablao, and Serra in