Case Summary (G.R. No. L-12084)
Background and Purchases
On March 21, 1951, Florencia de Guzman and Maria Santos purchased Lot No. 10 on an installment plan from the Philippine Realty Corporation. Pedro Samson entered into a separate agreement with the purchasers, committing to pay a share of the down payment and subsequent monthly installments related to the lot he occupied. Allegedly, Samson failed to honor his commitments, leading to de Guzman and Santos covering all payments until December 3, 1954, when they completed the purchase.
Initial Legal Action
On January 16, 1955, Samson initiated a lawsuit (Civil Case No. Q-1314) against de Guzman, Santos, and the Philippine Realty Corporation, asserting the existence of a partition agreement executed on June 15, 1951. He claimed this agreement entitled him to the portion of the lot he occupied. The defendants contested the claims, asserting that Samson's failure to pay installments constituted a waiver of his rights to the property.
Amicable Settlement
An "Amicable Settlement" was filed on December 15, 1955, detailing the division of the property and stipulating that Samson would receive a quarter of the lot. The agreement included a requirement for Samson to initiate the segregation of his allotted portion within three months, failing which he would lose all rights to the property.
Non-Compliance and Motions
On January 7, 1956, Samson transferred his rights to Mariano Reyes, his son-in-law, for P2,600. However, by May 8, 1956, de Guzman and Santos moved to have Samson's rights canceled due to his failure to commence segregation within the stipulated timeframe. The Court subsequently ordered the cancellation of Samson's rights on May 12, 1956, after he failed to appear for a motion hearing.
Reconsideration Attempts and Final Orders
Samson’s subsequent motions for reconsideration concerning the orders of cancellation and the requirement to vacate the property were denied, with the Court asserting that they had become final and executory. Samson's arguments, including the assertion that he had complied with the segregation requirement through a subdivision plan dated March 4, 1956, were dismissed.
Certiorari Petition
In response to the lower Court’s actions, Samson and Reyes filed a petition for certiorari, challenging several orders issued by the lower Court. The issue at hand was whether the lower Court had committed grave abuse of discretion in its earlier rulings, including its jurisdiction to enforce possession of the properties.
Court's Ruling on Jurisdiction and Orders
The Court determined that the orders issued were enforceable and did not constitute grave abuse of discretion. It was noted that disobedience to the amicable settlement terms initiated an execution of a final judgment. The Court emphasized that the orders only bound Pedro Samson personally and could not affect Mariano Reyes since he was not a party in the lower proceedings.
Dissenting Opinion
Justice Pad
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Case Overview
- The case involves a dispute over Lot No. 10, Block No. 45 of the Grace Park Subdivision in Caloocan, Rizal, owned by the Philippine Realty Corporation.
- Petitioners: Pedro Samson, Florencia Cruz Vda. de Guzman, and Maria Santos, the occupants of the lot.
- Respondents: Hon. Nicasio Yatco (Judge), Philippine Realty Corporation, Gregorio Velasquez (Register of Deeds of Rizal), and the Sheriff of Quezon City.
Background Facts
- On March 21, 1951, Florencia de Guzman and Maria Santos purchased the lot on an installment basis from the Philippine Realty Corporation.
- Pedro Samson entered an agreement with Guzman and Santos to pay part of the down payment and monthly installments for the portion he occupied, which he failed to fulfill.
- The lot was divided among the occupants in a partition agreement on June 15, 1951, but it was not approved by the Philippine Realty Corporation.
Legal Proceedings
- On January 16, 1955, Samson filed a complaint against Guzman, Santos, and the Philippine Realty Corporation, claiming rights over the property based on the partition agreement.
- Defendants denied the claims and filed a counterclaim for moral damages and attorney’s fees.
- An amicable settlement on December 15, 1955, was reached, wherein Samson was assigned a 1/4 portion of the lot, with conditions for segregation and payment of a purchase price.
Compliance Issues
- Samson sold his rights over the 1/4 portion of the property