Case Summary (G.R. No. 94918)
Key Dates
• 1955 – Death of Marcelo Suarez; estate remained unpartitioned.
• 1977 – Final judgment against Teofista Suarez (widow) and Rizal Realty Corp. for P70,000 damages.
• June 24, 1983 – En masse levy and auction sale of all five parcels; private respondents bid P94,170.
• August 1, 1983 – Registration of Certificate of Sale.
• June 21, 1984 – Petitioners file reinvindicatory action (RTC Civil Case No. 51203).
• February 25, 1985 – RTC issues preliminary injunction.
• May 29, 1986 – Branch 155 dismisses complaint for failure to prosecute; later lifted June 10, 1987.
• July 27, 1990 – Court of Appeals grants certiorari, annuls injunction orders, and dismisses Civil Case No. 51203.
• September 2, 1992 – Supreme Court decision reversing the Court of Appeals.
Procedural History
Following the 1977 judgment against their mother, the five patrimonial lots co-owned by the petitioners were levied in 1983 and sold en masse. Petitioners promptly initiated a reinvindicatory action to annul the sale as strangers to the underlying judgment and co-owners whose interest could not be attached in full. The RTC granted a preliminary injunction but later dismissed the case for alleged failure to prosecute. Upon reinstatement by motion, respondents secured an appellate certiorari relief annulling the injunctions and ordering dismissal. The petition to the Supreme Court challenged the Court of Appeals’ annulment of procedural safeguards protecting the petitioners’ proprietary interests.
Legal Issue
Whether the entire interest of co-owners (petitioners) may be levied and sold to satisfy a judgment exclusively binding on the surviving spouse’s half-share, and whether petitioners—being co-owners and strangers to the original suit—retain standing to annul the auction sale as to their own undivided shares.
Applicable Law
1987 Constitution (property rights and due process guarantees)
Civil Code (pre-1987 provisions):
• Article 777 – Transmission of succession rights upon death.
• Article 888 – Legitimate children’s legitime equals one-half of the hereditary estate; the decedent may dispose of the remaining half.
• Article 892(2) – Surviving spouse’s legitime equals that of each legitimate child.
Supreme Court Ruling
- Only the half-share of the estate subject to the decedent-mother’s disposable portion could be levied; petitioners’ one-half undivided interest was immune from execution against the mother alone.
- Petitioners’ proprietary
Case Syllabus (G.R. No. 94918)
Facts of the Case
- Petitioners are the legitimate children and co-owners of five parcels of land in Pasig, Metro Manila, registered under the name of their deceased father, Marcelo I. Suarez, whose estate has not been partitioned or liquidated since his death in 1955.
- In 1977, Teofista Suarez (widow of Marcelo Suarez) and Rizal Realty Corporation were sued for rescission of contract and damages, resulting in a final judgment ordering them to pay respondents approximately ₱70,000 as damages.
- To satisfy the judgment debt, the five parcels—valued at millions of pesos—were levied and sold en masse at public auction on June 24, 1983. Private respondents were the highest bidder at ₱94,170, and a certificate of sale was issued and registered on August 1, 1983.
Procedural History
- June 21, 1984: Petitioners filed a reinvindicatory action (Civil Case No. 51203) to annul the en masse auction sale and recover ownership of the properties, alleging their co-ownership rights as strangers to the underlying judgment.
- July 31, 1984: The Provincial Sheriff of Rizal executed and delivered the final deed of sale in favor of private respondents.
- October 22, 1984: Teofista Suarez, joined by petitioners, moved for reconsideration in Branch 151, RTC of Pasig, contesting the sale and informing the court of the pending annulment action; motion was denied.
- February 25, 1985: Branch 151 issued a writ of preliminary injunction enjoining private respondents from transferring the levied parcels, finding that the lands were co-owned by petitioners.
- Marc