Case Summary (G.R. No. 146839)
Factual Background
Humberto Meer, the registered owner of a property in Pandacan, Manila, discovered in June 1993 that his original Certificate of Title (TCT No. 158886) was cancelled and a new title (TCT No. 166074) was issued in favor of spouses Sergio and Lerma Bunquin. The Bunquins allegedly acquired the property via a deed of sale dated June 3, 1985, supposedly executed by Meer. Subsequently, Meer initiated proceedings to cancel TCT No. 166074, and a lis pendens was annotated on the title on January 12, 1994. Amid this pending litigation, on June 15, 1994, TCT No. 166074 was cancelled and TCT No. 216518 was registered in favor of the petitioners, spouses Michaelangelo and Grace Mesina, who had purchased the property from Lerma Bunquin on September 28, 1993—prior to the annotation of lis pendens—although registration was delayed due to requirements imposed by the National Housing Authority. The Bunquins did not participate in the trial, but petitioners actively defended their claim.
Trial Court Findings
The Metropolitan Trial Court (MeTC), Manila, ruled on February 16, 1998, that the alleged sale between Meer and the Bunquins was fraudulent, specifically determining that the Bunquins’ ownership was invalid. However, the petitioners Mesina were considered buyers in good faith due to their reliance on the title and their verification efforts, entitling them to possession of the property. The court cited established jurisprudence emphasizing that purchasers can rely on the Torrens certificate and are not required to investigate beyond it. Accordingly, the complaint against the Mesinas was dismissed, and the Bunquins were ordered to pay damages and attorney’s fees to Meer.
Regional Trial Court Reversal
Upon respondent Meer’s appeal, the Regional Trial Court (RTC), Manila, reversed the MeTC decision. It held that the Mesinas were not purchasers in good faith because the decisive factor was the date of registration of the deed of sale, not the date of its execution. Since the Mesinas’ registration occurred after the lis pendens had been annotated, they were bound by the outcome of the case regarding the Bunquin title. The RTC ordered cancellation of Mesinas’ title (TCT No. 216518), annulled the sale, and restored Meer’s original title (TCT No. 158886).
Court of Appeals Resolution and Motion for Relief from Judgment
The Court of Appeals (CA) affirmed the RTC ruling on May 10, 2000. Petitioners filed a Petition for Relief from Judgment after the reglementary period, asserting: (a) extrinsic fraud due to alleged collusion preventing them from presenting their case; (b) mistake and excusable negligence causing their failure to file a timely appeal; and (c) existence of good and substantial defense. The CA denied this petition, reasoning that claims of extrinsic fraud should have been addressed before the trial court pursuant to Section 1, Rule 38 of the Rules of Civil Procedure, and the petition was improperly filed to challenge a CA appellate judgment; thus, the petition lacked merit.
Issue Before the Supreme Court
The principal issue was whether a Petition for Relief under Rule 38 of the Rules of Civil Procedure is available as a remedy against a judgment issued by the Court of Appeals in the exercise of its appellate jurisdiction, and, if so, whether the petitioners’ grounds for relief were sufficient.
Supreme Court’s Legal Analysis on Petition for Relief
Relief from judgment under Rule 38 is an equitable remedy granted only in exceptional circumstances involving fraud, accident, mistake, or excusable negligence. It must be filed within 60 days from learning of the judgment and must be filed in the same court that rendered the decision. Rule 38 was amended in the 1997 Revised Rules of Civil Procedure to allow the same trial court that rendered the judgment to entertain petitions for relief; previously such petitions from municipal trial courts were filed in the regional trial courts.
The Supreme Court clarified that this amendment does not extend relief from judgment petitions to judgments of the Court of Appeals or Supreme Court. The term “any court” in Rule 38 refers only to municipal/metropolitan and regional trial courts. The special appellate procedures and remedies of the CA and the Supreme Court are governed by separate rules and internal regulations which do not provide for relief from judgment petitions after appellate decisions.
Application of the Rule to the Present Case
Petitioners failed to avail themselves of appropriate remedies at the initial trial and appellate levels. Allegations of extrinsic fraud should have been raised in the Metropolitan Trial Court, yet petit
...continue readingCase Syllabus (G.R. No. 146839)
Background and Procedural Posture
- Petitioners Spouses Michaelangelo and Grace Mesina filed a Petition for Review under Rule 45 of the Rules of Court, contesting two Resolutions of the Court of Appeals dated October 10, 2000 and January 26, 2001.
- The case arose from a dispute over the ownership of a parcel of land located at Lot 15, Block 5, Pandacan, Manila, originally titled to respondent Humberto D. Meer under TCT No. 158886.
- Respondent discovered his title had been cancelled and replaced by TCT No. 166074 in favor of spouses Sergio and Lerma Bunquin, who claimed acquisition by a deed of sale said to be executed by respondent in their favor on June 3, 1985.
- Respondent initiated an action for cancellation of TCT No.166074 and restoration of his title on January 12, 1994; simultaneously, a notice of lis pendens was annotated on TCT No. 166074.
- During the pendency of the case, on June 15, 1994, the title was further cancelled and reissued as TCT No. 216518 to petitioners, evidencing a conveyance executed on September 28, 1993 by the Bunquins to the Mesinas.
- Petitioners actively defended their position; the Bunquins defaulted after failure to appear.
Findings and Decisions of the Trial Court
- The Metropolitan Trial Court (MeTC) ruled in favor of petitioners as buyers in good faith despite declaring the sale between Meer and Bunquin fraudulent.
- The decision emphasized that petitioners relied on the face of the Bunquins’ registered title, made verification with the National Housing Authority, and sought legal advice prior to purchase.
- Citing established jurisprudence (Director of Lands vs. Abache, Pino vs. CA), the court held that purchasers may rely on the certificate of title's correctness without further inquiry.
- The MeTC dismissed respondent’s complaint against the Mesinas and ordered Bunquins to compensate the respondent for the property value, exemplary damages, and attorney’s fees.
- Respondent’s motion for reconsideration was denied.
Ruling of the Regional Trial Court (RTC) on Appeal
- The RTC reversed the MeTC decision, ruling that petitioners were not purchasers in good faith.
- It stressed that the registration date of the Deed of Sale, not the execution date, governs the conferral of title.
- Because the registration of the deed from Bunquins to petitioners occurred after the annotation of lis pendens, petitioners were bound by the determination of the case.
- The RTC ordered cancellation of TCTs in favor of both the Bunquins (No. 166704) and petitioners (No. 216518), restoring respondent’s title.
- The RTC further awarded respondent attorney’s fees and dismissed petitioners’ counterclaim.