Case Summary (G.R. No. 222537)
Antecedent Facts
The case began with Felias filing a Complaint for Recovery of Ownership and Possession against the Lastimosas in 1990. Following the death of Romualdo Lastimosa in 1997, a motion was filed to substitute the deceased with his heirs. Ultimately, the RTC ruled in favor of the Heirs of Nivera, granting them ownership and possession of the properties in question. Notably, the Heirs of Lastimosa did not appeal this decision. Felicitas then sought annulment of the RTC’s ruling in 2006, claiming she was denied due process due to her exclusion from the initial proceedings.
Appeals and Rulings
The Court of Appeals dismissed Felicitas' annulment petition, stating that the RTC acquired jurisdiction over the original defendants, with the ruling binding all heirs. This judgment was affirmed by the Supreme Court and became final. Subsequently, the Heirs of Lastimosa filed a motion to prevent demolition actions based on a claim that Felicitas had a rightful share in the property, whereas the Heirs of Nivera moved for execution of the final decision. The RTC granted the latter request.
Legal Issues
The primary legal issue revolves around whether the issuance of a Writ of Execution and Demolition by the RTC was proper, given Felicitas' assertion that the judgment is invalid as she was not a party to the original case. She contends that her exclusion deprived her of due process and that the property in question is her family home and thus exempt from execution under Article 155 of the Family Code.
Arguments of the Parties
Felicitas argues that since she was not impleaded in the case, the judgment against her predecessors does not bind her. Conversely, the Heirs of Nivera assert that her claims were already settled, as she had previously admitted to not residing at the property in question. They emphasize that the subject property belonged to the Heirs of Nivera since the 1950s, which disputes the characterization of the land as Felicitas' family home.
Ruling of the Court
The Supreme Court ruled against Felicitas, affirming the decisions of the lower courts. The high court reiterated that a judgment becomes final and executory, rendering all claims subsequent to it moot unless based on grounds such as a void judgment or new compelling evidence. The Court also emphasized that the burden of proving exemptions to execution, such as designating a property as a family home, lies with the claimant. In this instance, Felicitas failed to substantiate her claim with sufficient evidence. The Court highlighted her admissions regarding her reside
...continue readingCase Syllabus (G.R. No. 222537)
Case Overview
- Court: Supreme Court of the Philippines
- Date: February 5, 2018
- G.R. No.: 213972
- Petitioner: Felicitas L. Salazar
- Respondents: Remedios Felias, on her own behalf and representing the other heirs of Catalino Nivera
Procedural History
- The case is a petition for review on certiorari under Rule 45 of the Revised Rules of Court, seeking to reverse the Decision dated December 6, 2013, and Resolution dated August 7, 2014, rendered by the Court of Appeals.
- The Court of Appeals affirmed the execution of a final and executory judgment issued by the Regional Trial Court (RTC) Branch 55 in Alaminos, Pangasinan.
Antecedent Facts
- On February 28, 1990, Remedios Felias, representing the heirs of Catalino Nivera, filed a complaint against the Spouses Romualdo and Felisa Lastimosa for recovery of ownership, possession, and damages concerning four parcels of land in Baruan, Agno, Pangasinan.
- Romualdo Lastimosa died on March 3, 1997, leading to a motion for substitution filed by Felisa and their children.
- On March 16, 2004, the RTC Branch 55 ruled in favor of the Heirs of Nivera, declaring them as absolute owners of the subject properties and ordering the Heirs of Lastimosa to vacate and surrender possession.
- The Heirs of Lastimosa did not appeal the ruling.
- Felicitas Salazar, daughter of Romualdo, along with other heirs, filed a Petition for Annulment of Judgment, claiming deprivation of due process due to non-impleading in the original case. The CA dismissed this petition on June 5, 2008, and the ruling was affirmed by the Supreme Court on June 3,