A.M. No. CA-15-53-J - Re: Catherine Damayo

Case Summary (A.M. No. CA-15-53-J)

Petitioners

Conchita S. Uy (wife of deceased Jaime Uy) and eight children who were impleaded in the quieting action and who challenge post‑judgment execution steps and the extent of their personal liability.

Respondents

Heirs and successors of Crispulo Del Castillo, original plaintiff in the quieting action, who obtained a final judgment declaring them owners of the subject land and monetary awards including attorney’s fees.

Key Dates and Procedural Posture

Quieting of Title filed November 12, 1996; Jaime Uy had died in 1990; RTC decision rendered April 4, 2003 adjudicating respondents owners and awarding damages and attorney’s fees; judgment became final and executory in April 2010 (Entry of Judgment dated May 4, 2010); writ of execution issued December 13, 2010 and Notice of Garnishment March 21, 2011; RTC orders of December 9, 2011 and May 17, 2012 resolved post‑judgment motions; Court of Appeals affirmed May 26, 2015; Supreme Court partly granted the petition on the terms discussed.

Applicable Law and Doctrines Cited

Primary procedural provisions: Rule 3, Rules of Court — Section 16 (death of a party; duty of counsel) and Section 20 (actions and contractual money claims). Rule 14 (service of summons) and doctrines of jurisdiction by service or voluntary submission. Substantive and remedial principles: finality and immutability of judgment, and the limited circumstances for relaxing that doctrine; authority concerning judicial admissions. The applicable constitutional framework is the 1987 Constitution (decision postdates 1990).

Factual Background of the Quieting Action

Respondent Crispulo filed a quieting of title, reconveyance, damages and attorney’s fees against Jaime and Conchita in 1996; Jaime had predeceased filing (d. 1990). The complaint was amended to implead Jaime’s children (the Uy siblings). Crispulo died during the case and his heirs were substituted as plaintiffs. The RTC ultimately declared respondents the owners of Lot 791, nullified the competing certificates of title, and awarded moral damages, litigation costs and attorney’s fees.

RTC Judgment and Monetary Awards

The RTC decision of April 4, 2003 declared respondents true owners, nullified Original Certificate of Title No. 576 and TCT No. 29129, and awarded moral damages and litigation costs of P20,000.00 each and attorney’s fees equal to 25% of the zonal value of Lot 791. That decision was appealed, and after denial of relief, became final and executory in 2010.

Post‑Judgment Execution and Petitioners’ Motions

Respondents sought issuance of a writ of execution and computed attorney’s fees using the 2010 zonal value (P3,500/sq.m. × 15,758 sq.m. = P55,153,000; 25% = P13,788,250). A Notice of Garnishment sought levy in that amount plus P20,000 each for moral damages and litigation costs. Petitioners filed an Omnibus Motion to quash the writ and sought re‑computation of attorney’s fees, and separately moved to quash the writ on jurisdictional grounds, asserting lack of summons and improper personal liability beyond Jaime’s estate.

RTC Orders on the Post‑Judgment Motions

On December 9, 2011 the RTC issued twin orders: (1) granted petitioners’ Omnibus Motion and nullified the Notice of Garnishment and set a hearing to determine the proper computation of attorney’s fees; and (2) denied the motion to quash for lack of timely jurisdictional objection in the trial proceedings. After hearing and position papers, the RTC by Order dated May 17, 2012 pegged attorney’s fees at P3,387,970.00 (25% of the 1996 zonal value) — the computation least onerous to petitioners — and denied reconsideration.

Petitioners’ Argument on Appeal to the Court of Appeals

Petitioners asserted: (a) they were never served with summons in the quieting action and therefore the writ of execution and any attempt to levy against them were void; (b) the writ and Notice of Garnishment improperly altered the terms of the RTC decision by seeking attorney’s fees based on a later zonal value; and (c) being impleaded as substitutes of a deceased defendant, respondents should have pursued Jaime’s estate pursuant to Section 20, Rule 3, rather than seeking personal liability beyond the heirs’ inheritance.

Court of Appeals’ Ruling

The CA affirmed the RTC. It relied on a 1997 manifestation by petitioners’ counsel (Atty. Alan C. Trinidad) expressly admitting receipt of summons with a copy of the amended complaint and that the previously filed answer served as answer to the amended complaint. The CA treated that as a conclusive judicial admission. The CA also held Section 20, Rule 3 inapplicable because it governs contractual money claims and situations where the defendant dies while the action is pending; the CA observed petitioners had ample opportunity to raise asserted errors on appeal but did not, invoking finality. Regarding the writ of execution, the CA distinguished the writ (which referenced the RTC decision without adding to it) from the Notice of Garnishment (which sought to levy a specific larger amount) and found the writ valid while voiding the notice insofar as it exceeded the decision.

Supreme Court’s Analysis — Judicial Admissions and Jurisdiction

The Supreme Court agreed with the CA that the 1997 Manifestation constituted a judicial admission binding on petitioners and precluding a contrary jurisdictional claim. It further found that petitioners’ active participation (filing an answer, adopting Conchita’s answer, having a sibling testify, and litigating to the Court) amounted to voluntary submission to the RTC’s jurisdiction, which estops them from later challenging personal jurisdiction. The limited denial of counsel’s authority was held to be an afterthought unsupported by the record.

Supreme Court’s Analysis — Substitution, Impleading, and Rule 3 Provisions

The Court carefully distinguished substitution under Section 16, Rule 3 (applies when a party dies while an action is pending) from impleading: because Jaime died years before the complaint was filed, his children were impleaded in their personal capacities rather than substituted. Accordingly, Section 20, Rule 3 (which addresses continuation and special procedures for money claims against estates when a defendant dies while a case is pending) did not apply. The Court concluded petitioners could be held liable in their personal capacities for the monetary awards arising from the quieting action.

Doctrine of Immutability

Case Syllabus (A.M. No. CA-15-53-J)

Citation and Court Composition

G.R. No. 223610; Decision dated July 24, 2017; reported at 814 Phil. 61; First Division.
Decision penned by Associate Justice Perlas-Bernabe, J.
CA decision under review: Decision dated May 26, 2015 and Resolution dated February 22, 2016 of the Court of Appeals in CAA G.R. SP No. 07120.
CA Decision at rollo pp. 41–57; CA Resolution at rollo pp. 58–60.
Lower court (RTC, Mandaue City, Branch 55) orders under review: twin Orders dated December 9, 2011 (records, Vol. 3, pp. 931–934 and 936–937) and Order dated May 17, 2012 (records, Vol. 3, pp. 1012–1013), both penned by Acting Presiding Judge Silvestre A. Maamo, Jr.

Parties

Petitioners: Conchita S. Uy and her children Christine Uy Dy, Sylvia Uy Sy, Jane Uy Tan, James Lyndon S. Uy, Irene S. Uy, Ericson S. Uy (included in the petition as one of the petitioners), Johanna S. Uy, and Jednathan S. Uy (collectively, the Uy siblings).
Original plaintiff in the underlying quieting case: Crispulo Del Castillo (deceased during pendency), substituted by his heirs: Paulita Manalad-Del Castillo, Cesar Del Castillo, Avito Del Castillo, Nila C. Duenas, Nida C. Latosa, Lorna C. Bernardo, Gil Del Castillo, Liza C. Gungob, Alma Del Castillo, and Gemma Del Castillo (respondents).
Deceased person whose interest is implicated: Jaime Uy (died March 4, 1990).

Nature of the Case and Relief Sought in the Underlying Action

Underlying action: Quieting of title, reconveyance, damages, and attorney’s fees concerning Lot 791 covered by Transfer Certificate of Title (TCT) No. 29129.
Original complaint filed by Crispulo on November 12, 1996 (records Vol. 1, pp. 1–7); Second Amended Complaint dated June 16, 1997 (records, pp. 47–54).
Relief awarded by RTC in the Quieting of Title Case included:
- Declaration that respondents are the true and lawful owners of Lot 791.
- Nullification of Original Certificate of Title No. 576 and TCT No. 29129.
- Award of moral damages and litigation costs of P20,000.00 each to respondents.
- Award of attorney’s fees equivalent to twenty-five percent (25%) of the zonal value of Lot 791.

Material Facts Pertaining to Title, Area, and Zonal Value

Lot involved: Lot 791.
TCT No.: 29129 (records, Vol. 1, pp. 8–9).
Area of Lot 791: 15,758 square meters (as used by parties for computations).
Zonal value figures referenced by parties and courts:
- Zonal value at time of filing (1996): used in computations (respondents’ option yielding P3,387,970.00 as 25%).
- Zonal value in 2003 (time of RTC Decision): alternative computation yielding P11,424,550.00 as 25%.
- Zonal value in 2010 (time of finality/execution): respondents computed zonal value at P3,500.00 per sqm → total zonal value P55,153,000.00 and 25% = P13,788,250.00; another stated 25% equivalent indicated at P15,758,000.00 in the record as alternative (see plaintiff’s position paper and rollo p. 46).

Procedural History — From RTC Quieting Decision to Execution

RTC rendered Decision in favor of respondents dated April 4, 2003 (rollo, p. 61–74), declaring respondents owners and awarding damages and attorney’s fees (25% of zonal value).
Petitioners appealed to the Court of Appeals and to the Supreme Court; appeals were denied for lack of merit, the RTC ruling became final and executory on April 8, 2010; Entry of Judgment dated May 4, 2010 (rollo, pp. 92–93).
Respondents filed Motion for Issuance of Writ of Execution on August 17, 2010 (rollo, pp. 94–97); asserted zonal value P3,500.00/sqm (rollo, pp. 95–96).
RTC ordered petitioners to comment; they did not (Order dated September 3, 2010; rollo, p. 103).
RTC issued Order granting motion and ordering issuance of writ of execution on November 22, 2010 (records, Vol. 3).
Writ of Execution issued December 13, 2010 (rollo, pp. 104–105); sheriff issued Notice of Garnishment dated March 21, 2011 seeking levy sufficient to cover P13,788,250.00 in attorney’s fees plus P20,000.00 each moral damages and litigation costs (rollo, p. 107).

Motions Filed by Petitioners in the Execution Stage

Omnibus Motion dated April 27, 2011 (rollo, pp. 110–137) seeking:
- Quashment and setting aside of the writ of execution.
- A hearing to re-compute attorney’s fees.
- Ground: writ invalid because it altered terms of RTC Decision which did not state that zonal value referred to the value at time of execution (rollo, pp. 132–133; see also pp. 44–45).
Motion to Quash Writ of Execution on Jurisdictional Ground(s) dated June 10, 2011 (rollo, pp. 147–177) claiming:
- RTC lacked jurisdiction over the Uy siblings because they were never served with summons in the Quieting of Title Case (rollo, pp. 172–173; p. 45).
Consolidated Motion for Reconsideration dated January 27, 2012 (rollo, pp. 230–290) reiterating:
- RTC failed to definitively rule on writ validity.
- RTC erred in holding that its Decision was final and executory despite alleged absence of summons on the Uy siblings.
- Petitioners contended they should not be held personally liable beyond their inheritance from Jaime and that respondents should have filed against Jaime’s estate pursuant to Section 20, Rule 3 of the Rules of Court (rollo, pp. 281–284; pp. 46–47).

RTC Orders of December 9, 2011 and May 17, 2012 — Dispositions and Rationale

RTC Orders dated December 9, 2011:
- One order granted petitioners’ Omnibus Motion, nullified the Notice of Garnishment, and set a hearing to determine proper computation of attorney’s fees (records, Vol. 3, pp. 931–934).
- Another order denied the motion to quash on jurisdictional grounds because petitioners had not earlier raised such jurisdictional issue in the proceedings a quo (records, Vol. 3, pp. 936–937).
Hearing conducted January 20, 2012; parties ordered to submit position papers (Order dated January 20, 2012; records, Vol. 3, p. 939).
Respondents’ position paper (Jan. 24, 2012) offered alternative computations for 25% attorney’s fees based on different zonal values: P3,387,970.00 (1996), P11,424,550.00 (2003), P15,758,000.00 (2010) (records, Vol. 3, pp. 940–942; rollo, p. 46).
RTC Order dated May 17, 2012 (records, Vol. 3, pp. 1012–1013):
- Pegged attorney’s fees at P3,387,970.00, using zonal value in 1996 (the computation least onerous to petitioners). (Clerical note: inadvertently indicated as “P3,387,470.00” in said Order; records, Vol. 3, p. 1013.)
- Denied petitioners’ Consolidated Motion for Reconsideration for lack of merit.

Court of Appeals Ruling (May 26, 2015) — Holdings and Reasoning

CA affirmed the RTC’s twin Orders and the May 17, 2012 Order (rollo, pp. 41–57).
On service of summons and representation:
- CA relied on a Manifestation/Motion dated November 26, 1997 (records, Vol. 1, pp. 64–65) in which petitioners, through their counsel Atty. Alan C. Trinidad, stated they “received the Summons with a copy of the Second Amended Complaint” and that the earlier Answer serves as answer to the Second Amended Complaint (rollo, p. 52).
- CA found petitioners’ later denial of Atty. Trinidad’s representation unpersuasive because one petitione