Case Summary (A.M. No. RTJ-13-2360)
Essential Facts and Antecedent Proceedings
The subject property, originally owned by Guillermo Lucero's parents (Marcos and Tomasa), was mortgaged to the Development Bank of the Philippines due to a loan default, leading to an extrajudicial foreclosure. Despite this, a repurchase agreement allowed the parents to regain ownership before selling the lot to Guillermo. Meanwhile, Lino Rebamonte claimed ownership of three hectares of Lot No. 1305-A through alleged sales from Tomasa and Guillermo's sisters, albeit these sales were unregistered. Guillermo, demanding possession of his property, filed a complaint against the petitioners, leading to litigation in the RTC.
Ruling of the RTC
On February 3, 2012, the RTC declared the deeds of sale from Guillermo's sisters to Lino as null and void, stating that they had no right to sell the property due to the parents being the rightful owners at the time of the transactions. Conversely, the RTC recognized the sale from Tomasa to Lino as valid. Consequently, the RTC ordered the petitioners to vacate the disputed portions and allocated damages to the respondents.
Ruling of the Court of Appeals
The Court of Appeals upheld the RTC's decision, denying the petitioners' appeal for lack of merit. They confirmed that the two deeds from Guillermo's sisters were indeed void due to the lack of ownership rights at the time of sale.
Issues Raised by Petitioners
The petitioners raised several issues before the Supreme Court, primarily questioning the jurisdiction of the RTC based on the assessed property value, alleging defective service of summons, and asserting that the failure to substitute a deceased party rendered the RTC's decision null and void.
The Court's Ruling on Jurisdiction
Initially, the petitioners contended that the RTC lacked jurisdiction because the assessed value of the subject portions was below the threshold for RTC cases, thus falling under the jurisdiction of the Municipal Trial Court. However, they were barred from raising this argument at this late stage due to the doctrine of estoppel by laches as they had actively participated in the proceedings without previously asserting a lack of jurisdiction.
The Court's Ruling on Service of Summons
The petitioners' claim regarding defective service of summons was dismissed by the Supreme Court, which noted that their voluntary appearance was tantamount to proper service. The petitioners had engaged fully in the trials and proceedings, thereby undermining their claim of insufficient service.
The Court's Ruling on Substitution of a Deceased Party
The Supreme Court addressed the petitioners' assertion that the death of respondent Guillermo in 2000 warranted a nullification of the RTC decision due to unaddressed substitution. The Court clarified that the failure to substitute a party does not automatically void a judgment unless i
...continue readingCase Syllabus (A.M. No. RTJ-13-2360)
Introduction
- The case revolves around a dispute over two portions of land that were originally part of a larger lot owned by Guillermo Lucero and his family.
- The petitioners, heirs of Lino Rebamonte, contest the validity of sales made by Guillermo’s relatives, which they claim gave them rightful ownership of these land portions.
- The Supreme Court evaluates jurisdictional issues and the validity of previous court decisions in light of the principles of estoppel and laches.
Essential Facts and Antecedent Proceedings
- The subject lands are part of Lot No. 1305-A, registered under Transfer Certificate of Title (TCT) No. T-17712 in Guillermo Lucero’s name.
- The original lot, previously owned by Guillermo's parents, was mortgaged and subsequently foreclosed by the Development Bank of the Philippines due to non-payment.
- Guillermo's parents repurchased the lot, which was later sold to Guillermo.
- Before this sale, Lino Rebamonte claims he purchased portions of the lot from Guillermo's relatives under unregistered sales.
- The conflict led to a legal complaint by Guillermo and his wife seeking recovery of possession of the lot.
The Ruling of the RTC
- The RTC voided the two sales from Guillermo’s sisters to Lino, ruling they had no authority to sell the property.
- The court upheld the validity of the sale from Tomasa to Lino for one hectare.
- The RTC ordered the petitioners to vacate the disputed portions and affirmed Gui