Case Summary (G.R. No. L-39272)
Historical Background of Ownership
The Lot 6 in question has a complex ownership timeline. The Philippine Realty Corporation initially owned the lot under Original Certificate of Title No. 868, issued in 1916. Mangahas and Ramos illegally occupied the lot in 1949, leading them to file Civil Case No. C-120 in 1964 against Philippine Realty Corporation and Magbanua to annul a sale of the land. In 1969, the court ruled against them, mandating them to vacate the property. After multiple appeals by Mangahas and Ramos, the Supreme Court upheld the lower court's decision in 1973, which allowed the Philippine Realty Corporation to finalize its sale of the property to Magbanua.
Subsequent Transactions and Legal Actions
In October 1973, Salamat purchased Lot 6 from the heirs of Don Mariano San Pedro y Esteban. The subsequent use of the lot for housing prompted further disputes. In January 1974, following the illegal occupation by Mangahas and Ramos, Magbanua initiated a motion for demolition after they refused to vacate, asserting her registered ownership under Transfer Certificate of Title No. 52262. In response, Salamat filed an affidavit claiming ownership as the current possessor of the houses located on the land.
Demolition Orders and Legal Challenges
The court, upon evaluating the motions and oppositions filed, issued a writ of demolition after initially granting a 20-day window for Mangahas to remove her improvements. Salamat attempted to intervene in the proceedings, citing her rights as a good-faith purchaser. Despite her motions for reconsideration, the court denied her requests and issued additional demolition orders throughout 1974.
Legal Principles Invoked
The core legal matter revolved around the enforceability of the 1969 court judgment in Civil Case No. C-120 against Salamat, who was not a party to that case. Salamat’s contention rested on the principle that non-parties to a case are generally not bound by its judgments. Established jurisprudence supports that execution can only be issued against parties involved in the original action (e.g., Ed. A. Keller & Co. v. Edlerman, Bien v. Sunga, and others).
Conclusion on Ownership Claims and Demolition Rulin
...continue readingCase Syllabus (G.R. No. L-39272)
Case Overview
- This case involves a petition for review on certiorari and injunction with a prayer for a restraining order filed by Eugenia Salamat Vda. de Medina against Honorable Fernando A. Cruz, presiding judge of the Court of First Instance of Rizal, and Remedios Magbanua.
- The petition seeks to annul the writ of demolition issued by the respondent judge in Civil Case No. C-120, against which the petitioner claims ownership of the property in question.
- The decision was rendered on May 4, 1988, by Justice Paras.
Background of the Case
- The case originates from Civil Case No. C-120 involving the lot in Grace Park Subdivision, Caloocan City, originally covered by Original Certificate of Title No. 868, issued to the predecessor of the Philippine Realty Corporation.
- In 1949, Benedicta Mangahas and Francisco Ramos occupied the lot without the consent of the registered owner, leading to subsequent legal disputes.
- On April 27, 1959, the Philippine Realty Corporation sold the lot to Remedios Magbanua via a Contract to Sell.
- Mangahas and Ramos later filed a complaint for annulment of the sale, which was dismissed in 1969, leading to a final court decision by 1973.
Petitioner’s Acquisition of the Property
- On October 16, 1973, petitioner Eugenia Salamat vda. de Medina purchased the same lot from the heirs of Don Mariano San Pedro y Esteban.
- The p