Case Summary (G.R. No. 219984)
Facts and Antecedent Proceedings
Petitioner FACOMA initiated legal action for quieting of title and recovery of ownership and possession of a parcel of land against the respondents and Francisco Estrada. The Regional Trial Court (RTC) of Malaybalay City issued a decision on December 3, 2010, in favor of FACOMA, ordering the annulment of a deed of sale in favor of Amante Cabotaje and restoration of ownership to FACOMA. The respondents filed a Motion for Reconsideration, arguing that FACOMA lacked legal capacity to sue and claiming the validity of the deed of sale. The RTC denied the Motion for Reconsideration on February 3, 2011. Subsequently, the respondents filed a Notice of Appeal, which FACOMA moved to dismiss, contending it was filed out of time as their earlier Motion for Reconsideration was deemed pro forma. The RTC denied the Notice of Appeal on April 4, 2011, prompting the respondents to file a Petition for Certiorari before the Court of Appeals (CA).
Ruling of the Court of Appeals
The CA reversed the RTC's ruling and granted the respondents' Certiorari Petition, determining that the Motion for Reconsideration was not pro forma, thus allowing the Notice of Appeal to proceed. The CA set aside the RTC's Resolution dated April 4, 2011, thereby instructing the RTC to give due course to the respondents' Notice of Appeal. The decision was reaffirmed in a subsequent resolution which FACOMA sought to overturn through a Petition for Review.
Issues Presented
The main issues raised by FACOMA included:
- Whether the CA erred in holding that the Certiorari Petition assailed the RTC's Resolution dated April 4, 2011.
- Whether the CA erred in holding that the Notice of Appeal was wrongly denied by the RTC on the grounds that the respondents' Motion for Reconsideration was not pro forma.
- Whether the CA erred by failing to declare the Certiorari Petition moot due to the RTC's granting of FACOMA's Motion for Execution of Judgment.
Analysis of the Court's Ruling
Scope of the Certiorari Petition: The Court acknowledged that the CA correctly found that the Certiorari Petition targeted the RTC's April 4, 2011 Resolution, not the December 3, 2010 Decision. The CA's determination was grounded in substantial evidence, thus binding under the principles of appellate review.
Nature of the Motion for Reconsideration: The Court concurred with the CA that the Motion for Reconsideration filed by the respondents was not a pro forma motion. The mere reiteration of issues raised previously does not automatically categorize a motion as pro forma. The findings concluded that the respondents presented substantive arguments justifying their Motion for Reconsideration concerning FACOMA's legal capacity to sue.
Case Syllabus (G.R. No. 219984)
Overview of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court filed by petitioner Valencia (Bukidnon) Farmers Cooperative Marketing Association, Inc. (FACOMA).
- The petitioner, represented by its Board of Directors led by David M. Porticos, challenges the Decision dated March 27, 2014, and the Resolution dated August 13, 2015, both issued by the Court of Appeals in CA-G.R. SP No. 04244-MIN.
- The main contention of the petitioner is the reversal of the Regional Trial Court’s (RTC) Resolution dated April 4, 2011, which denied the Notice to Appeal filed by the respondents Heirs of Amante P. Cabotaje.
Facts and Antecedent Proceedings
- Petitioner FACOMA, through Directors Sergio Belera and Pedro Pagonzaga, initiated an action against respondents Heirs of Cabotaje and Francisco Estrada for quieting of title, recovery of ownership and possession, and damages.
- On December 3, 2010, the RTC rendered a Decision in favor of FACOMA, which included annulment of the Deed of Sale executed by Francisco Estrada in favor of Amante Cabotaje.
- The Decision also ordered the demolition of improvements made in bad faith and restoration of the Certificates of Titles to FACOMA.
- Respondents Heirs of Cabotaje filed a Motion for Reconsideration, raising three main arguments against the RTC's ruling, including FACOMA's alleged lack of legal personality to sue.
- The RTC denied the Motion for Reconsideration on February 3, 2011.
- Following the denial, respondents filed a Notice of Appeal on February 25, 2011. However, FACOMA move