Case Summary (G.R. No. 121157)
Property and Lease Context
Following the intestate death of Abelardo Escueta on December 3, 1994, his estate, including a property in Mandaluyong City, was to be shared among his widow and their six children. The property was initially leased to Rainier Llanera, who sublet it to 25 individuals. The heirs executed an extra-judicial settlement to manage the property, including granting Ma. Teresa Escueta the authority to sell it.
Execution of Settlements and Agreements
In 1999, the heirs entered a deed of conditional sale with Mary Liza Santos, establishing payment terms contingent on the vacating of the property by the lessees. Following the agreement, an "Amicable Settlement" was executed on May 5, 1999, where the sub-lessees agreed to vacate by December 1999 in exchange for the landlord ceasing rental collections.
Enforcement of the Amicable Settlement
Despite the amicable arrangement, several sub-lessees, including the petitioners, failed to vacate the property by the agreed date. In response to their continued presence, Escueta moved for an execution in the Metropolitan Trial Court (MTC) to enforce the settlement, which was met with opposition from the sub-lessees claiming they had not violated any terms of their lease.
Trial Court's Rulings
Initially, the MTC denied Escueta's motion for execution, asserting she was not the real party-in-interest since ownership of the property had been transferred to new buyers. Aggrieved, Escueta appealed to the Regional Trial Court (RTC), which ultimately ruled in her favor—reinforcing her standing as the real party-in-interest due to ongoing financial obligations tied to the conditional sale contingent upon the sub-lessees' departure.
Court of Appeals Decision
The petitioners filed a review with the Court of Appeals, challenging procedural grounds and the handling of ejectment rights. However, the appellate court dismissed their petition, agreeing with the RTC that Escueta maintained the right to enforce the amicable settlement.
Claims of Impropriety and Appeals
The petitioners alleged coercion in signing the settlement and asserted a right of first refusal under Presidential Decree No. 1517, which was linked to urban land reform. Nevertheless, the RTC found that the property was not under any designated urban land reform area, thus negating their claims.
Supreme Court's Ruling
The Supreme Court ultimately denied the petition, reinforcing the findings of the lower courts regarding the real party-in-interest and the lack of a valid claim to the right of first refusal under urban land reform laws. Th
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Case Background
- This case arises from a petition for review of the Decision dated July 23, 2002, of the Court of Appeals in CA-G.R. SP No. 68895.
- The Court of Appeals affirmed the decision of the Regional Trial Court (RTC) of Mandaluyong City, Branch 208, which had reversed a previous ruling by the Metropolitan Trial Court (MTC) of Mandaluyong City, Branch 60.
- The RTC granted a motion for execution filed by the private respondent Ma. Teresa O. Escueta in Civil Case No. 17520.
Antecedents
- Abelardo Escueta died intestate on December 3, 1994, survived by his widow, Remedios Escueta, and their six children, including Ma. Teresa O. Escueta.
- The estate included a parcel of land in Mandaluyong City, covered by Transfer Certificate of Title (TCT) No. 27568, which was leased to Rainier Llanera and sublet to 25 individuals.
- The heirs executed an extra-judicial settlement of the estate and a special power of attorney authorizing Ma. Teresa Escueta to sell the property.
- In 1999, Ma. Teresa Escueta filed an ejectment case against Llanera and the sub-lessees before the Lupon of Barangay Highway Hills.
Conditional Sale and Amicable Settlement
- On April 15, 1999, the heirs executed a deed of conditional sale over the property to Mary Liza Santos for P13,300,000, with stipulated payment terms.
- The agreement allowed for the down payment to be acknowledged immediately and further payments contingent upon the publication of the estate settlement and the vacation of all occupants within six months.
- An "Amicable Settlement" was executed on May 5, 1999, where the defendants agreed to vacate the property by D