Title

Spouses Su vs. Bontilao

Case
G.R. No. 238892
Decision Date
Sep 4, 2019
Petitioners, registered owners of a Lapu-Lapu City property, sued respondents for
unlawful detainer, claiming possession by tolerance. Respondents contested
ownership, alleging fraud. Courts initially ruled for petitioners, but CA dismissed the
case due to procedural non-compliance. SC upheld CA, citing insufficient
evidence of tolerance and procedural lapses.

Facts:
The case involves the petitioners, Spouses Aurora Tojong Su and Amador Su, who filed
a complaint for unlawful detainer against the respondents, Eda Bontilao, Pablita
Bontilao, and Maricel Dayandayan, concerning a parcel of land located in Barrio Looc,
Lapu-Lapu City, with an area of approximately 2,830 square meters, covered by
Transfer Certificate of Title (TCT) No. 29490. The petitioners claimed ownership of the
property and alleged that the respondents had constructed houses on it and were
occupying it with the petitioners' mere tolerance, with the understanding that they
would vacate upon demand. The petitioners made formal demands for the respondents
to vacate the property, which were ignored. After unsuccessful attempts at an
amicable settlement, the petitioners filed their complaint on March 1, 2012, in the
Municipal Trial Court in Cities (MTCC) of Lapu-Lapu City.

In their defense, the respondents contended that the petitioners were not the real
owners of the property, asserting that the petitioners acquired their title through
fraud. They claimed to be the legitimate heirs of Mariano Ybañez, the original owner,
and argued that they had been in continuous possession of the property since their
youth. The MTCC initially dismissed the case due to the petitioners' failure to appear
at a preliminary conference. However, upon reconsideration, the MTCC reinstated the
case and eventually ruled in favor of the petitioners, ordering the respondents to
vacate the property. The respondents appealed to the Regional Trial Court (RTC),
which affirmed the MTCC's decision. The respondents then filed a motion for
reconsideration, which was denied, prompting them to appeal to the Court of Appeals
(CA).

The CA reversed the RTC's decision, dismissing the complaint on procedural grounds,
stating that the petitioners' absence at the preliminary conference warranted
dismissal. The petitioners subsequently filed a petition for review on certiorari before
the Supreme Court.

Issue:
1. Did the Court of Appeals err in reversing and setting aside the lower courts'
decisions and dismissing the complaint for unlawful detainer based on
procedural grounds?

Ruling:
The Supreme Court partly granted the petition, ruling that the Court of Appeals erred
in dismissing the complaint based solely on procedural considerations. The Court
reinstated the decisions of the MTCC and RTC in favor of the petitioners.

Ratio:
The Supreme Court emphasized that the absence of the petitioners at the preliminary
conference was excused due to the Special Power of Attorney (SPA) executed in favor
of their counsel, Atty. Amores, which granted him full authority to represent them. The
Court noted that the SPA was duly presented in the records, negating any claims of
belated execution. The Court clarified that the motion for reconsideration filed by Atty.
Amores was not a prohibited pleading, as it did not seek reconsideration of a judgment
rendered on the merits but rather addressed a procedural dismissal.

The Court further explained that while the failure to file a pre-trial brief could lead to
dismissal, the rules governing summary procedure allow for resolution based on
pleadings and position papers. The Court criticized the CA for rigidly applying
procedural rules at the expense of substantial justice, reiterating that cases should be
resolved on their merits rather than on technicalities. The Court concluded that the
petitioners had not intended to delay proceedings and had taken steps to comply with
court processes, thus justifying the reinstatement of the case for resolution on its
merits.
Title
Republic vs. Oleta
Case
G.R. No. 156606
Decision Date
Aug 17, 2007
The Republic of the Philippines sought land reversion; procedural lapses
in pre-trial led to dismissal and reinstatement. Supreme Court upheld
trial court's discretion, prioritizing substantial justice over technicalities.

Facts:

The case involves the Republic of the Philippines, represented by the

Regional Executive Director of the Department of Environment and Natural
Resources, as the petitioner, and Ildefonso T. Oleta as the respondent. The
events leading to this case began on December 29, 1999, when the
petitioner filed a complaint for the cancellation of a free patent, original
certificate of title, and reversion against Oleta and the Register of Deeds of
Rizal. Oleta responded to the complaint on April 17, 2000. Subsequently, on
July 4, 2000, the Regional Trial Court (RTC) issued an order directing the
petitioner to expedite the case. However, on January 11, 2001, the RTC
dismissed the complaint without prejudice due to the petitioner's failure to
set the case for pre-trial. Following a motion from the petitioner, the RTC
reinstated the complaint on March 15, 2001, and set a pre-trial for May 17,
2001.

On May 8, 2001, the petitioner requested to reset the pre-trial to June 14,
2001, which the RTC granted. The RTC warned that failure to appear would
lead to appropriate action. However, on June 14, 2001, neither the
petitioner nor its counsel appeared, and the RTC dismissed the complaint
for failure to prosecute. The petitioner filed a motion for reconsideration,
explaining that the counsel arrived late and that the pre-trial brief was sent
by registered mail on June 8, 2001. The RTC reinstated the complaint on
July 24, 2001, but Oleta filed an urgent motion for reconsideration, claiming
the RTC acted with grave abuse of discretion. The Court of Appeals, in its
decision dated July 30, 2002, set aside the RTC's orders, stating that the
RTC abused its discretion by reinstating the complaint despite the absence
of a special power of attorney for the counsel. The petitioner’s motion for
reconsideration was denied on January 3, 2003, leading to the current
petition for review on certiorari.

Issue:

Did the Court of Appeals err in setting aside the RTC's orders dated July 24,
2001, and September 6, 2001, which reinstated the complaint filed by the
petitioner?

Ruling:

The Supreme Court granted the petition, reinstating the RTC's orders dated
July 24, 2001, and September 6, 2001. The Court ruled that the Court of
Appeals erred in its decision.

Ratio:

The Supreme Court emphasized that under Section 6, Rule 18 of the Rules
of Court, parties are required to file pre-trial briefs at least three days
before the scheduled pre-trial, and failure to do so is treated as a failure to
appear. The Court clarified that while the RTC has the discretion to dismiss
a case for failure to appear, it also retains the discretion to lift a dismissal if
justified by the circumstances. In this case, the petitioner provided a
reasonable explanation for the late filing of the pre-trial brief, which was
beyond its control.

Regarding the absence of a special power of attorney, the Court noted that
while the counsel admitted to not having one, the new rules require such
authority to be in writing. However, the Court found that the trial court did
not gravely abuse its discretion in reinstating the complaint, as there was
no evidence of willful disregard for the court's authority or lack of interest
in prosecuting the case. The Court underscored the importance of
substantial justice, stating that both parties should have the opportunity to
fully litigate their claims. Thus, the Supreme Court reinstated the RTC's
orders, allowing the case to proceed.
Title
Suico Industrial Corp. vs. Lagura-Yap
Case
G.R. No. 177711
Decision Date
Sep 5, 2012
PDCP Bank foreclosed Suico properties; petitioners claimed repurchase
agreement. Case dismissed for failure to file pre-trial brief; appeal
denied as untimely. SC upheld dismissal, citing procedural rules and
counsel's negligence.

Facts:
The case involves a petition for review on certiorari filed by Suico Industrial
Corporation and spouses Esmeraldo and Elizabeth Suico against Hon.
Marilyn Lagura-Yap, the Presiding Judge of the Regional Trial Court (RTC)
of Mandaue City, Branch 28, along with Private Development Corporation of
the Philippines (PDCP Bank, now First E-Bank) and Antonio Agro
Development Corporation (AADC) as respondents. The events leading to
this case began in 1993 when PDCP Bank foreclosed on two real estate
properties in Mandaue City owned by the petitioners due to their failure to
pay loans secured in 1987 and 1991. PDCP Bank emerged as the highest
bidder in the foreclosure sale, leading to the issuance of Transfer Certificate
of Title Nos. 34987 and 34988 in its name after the petitioners failed to
redeem the properties within the legal timeframe.

On January 17, 1995, the petitioners obtained an injunctive writ from RTC
Branch 56 to prevent PDCP Bank from taking possession of the properties,
claiming an agreement with the bank to allow them to repurchase the
properties after foreclosure. However, the Court of Appeals (CA) later ruled
that the issuance of the injunctive writ was beyond the jurisdiction of RTC
Branch 56, as it interfered with the proceedings of RTC Branch 28, which
had jurisdiction over the foreclosure case. The CA's decision was affirmed
by the Supreme Court in 1999, establishing that PDCP Bank had a clear
right to possess the properties due to its ownership following the
foreclosure sale.
Despite this, the petitioners continued their case for specific performance,
injunction, and damages in RTC Branch 56. AADC, which purchased the
properties from PDCP Bank, sought to intervene in the case. The case was
eventually transferred to RTC Branch 55, where the presiding judge allowed
the defendants time to file their oppositions. However, the petitioners
moved to declare PDCP Bank in default for not filing an answer. The RTC
denied this motion and later dismissed the case due to the petitioners'
failure to file a pre-trial brief, which was deemed equivalent to failing to
appear at the pre-trial conference. The petitioners' motion for
reconsideration was denied, and their subsequent notice of appeal was filed
late, leading to the CA's dismissal of their petition for lack of merit.

Issue:
1. Did the RTC commit grave abuse of discretion in declaring the
petitioners non-suited and dismissing their case for failure to file a
pre-trial brief?
2. Was the petitioners' notice of appeal filed out of time, thus
invalidating their appeal?

Ruling:
1. The Supreme Court ruled that the RTC did not commit grave abuse of
discretion in dismissing the case for failure to file a pre-trial brief.
2. The Court found that the petitioners' notice of appeal was timely filed,
as it was within the fifteen-day period from their receipt of the order
denying their motion for reconsideration.

Ratio:
The Supreme Court emphasized the importance of adhering to procedural
rules, particularly regarding pre-trial requirements. The failure to file a pre-
trial brief is a valid ground for dismissal, as outlined in the Rules of Court.
The Court noted that the petitioners' counsel had a duty to comply with
these rules, and their negligence in failing to file the required brief was
binding on the petitioners. The Court also highlighted that procedural rules
are designed to ensure the orderly and efficient administration of justice,
and disregard for these rules cannot be justified without compelling
reasons.
Regarding the timeliness of the appeal, the Court applied the "fresh period
rule" established in Neypes v. Court of Appeals, which allows a party to file
a notice of appeal within fifteen days from the receipt of the resolution
denying a motion for reconsideration. The Court found that the petitioners
had indeed filed their notice of appeal within this period, thus validating
their appeal. However, the Court ultimately affirmed the dismissal of the
case based on the procedural missteps of the petitioners, reiterating that
the alleged agreement with PDCP Bank lacked sufficient proof and did not
warrant a relaxation of the rules.

Title
Ramos vs. Spouses Alvendia
Case
G.R. No. 176706
Decision Date
Oct 8, 2008
Petitioner alleges fraud in land transfer, claims mental incapacity; case
dismissed for procedural lapses, but Supreme Court reverses,
prioritizing substantial justice over rigid rules.

Facts:
The case involves Manigo K. Ramos as the petitioner against the spouses
Purita G. Alvendia and Oscar Alvendia, as well as spouses Jose and Araceli
Severino, who are the respondents. The events leading to the case began
when Ramos and his brother, Jose Orlando Ramos, Jr., were the registered
owners of three parcels of land in Las Piñas, covered by Transfer Certificate
of Titles (TCT) Nos. 336585, 33875, and 24162-A. After Orlando's death on
December 25, 1987, the titles went missing. Petitioner claimed that he was
misled by a neighbor, Hermilina Calasan, into allowing her to reconstitute
the titles, believing he was signing mortgage documents. Instead, Hermilina
allegedly colluded with Purita Alvendia to execute two Deeds of Donation in
1995, falsely indicating that the lands were donated to Purita. This led to
the cancellation of the original titles and the issuance of new titles in the
names of the Alvendias, who later transferred the properties to the
Severinos.

On April 24, 1997, Ramos filed a complaint in the Regional Trial Court
(RTC) of Las Piñas for the cancellation of the Severinos' titles and the
reconveyance of the properties. He attached a psychological report
indicating his mental incompetence, which stated that he had a mental age
of 9 to 10 years. The respondents countered that they acquired the
properties through valid sales from Ramos. The pre-trial was initially set for
September 7, 1998, but was rescheduled to October 1, 1998, due to the
absence of the Alvendias. On the rescheduled date, the trial court declared
Ramos non-suited for his counsel's failure to appear and for not filing a pre-
trial brief. Ramos filed a motion for reconsideration, explaining his counsel's
late arrival and the non-filing of the pre-trial brief due to unforeseen
circumstances. The RTC denied the motion, leading to an appeal to the
Court of Appeals, which affirmed the trial court's decision.

Issue:
1. Did the trial court err in declaring the petitioner non-suited for the
failure of his counsel to appear during the pre-trial and to file a pre-
trial brief?
2. Should the dismissal of the complaint be reversed in light of the
petitioner's mental incompetence and the circumstances surrounding
the case?

Ruling:
1. The Supreme Court ruled that the trial court's declaration of the
petitioner as non-suited was too hasty and not justified by the
circumstances.
2. The dismissal of the complaint was reversed, and the case was
remanded to the RTC for further proceedings.

Ratio:
The Supreme Court emphasized that the dismissal of a case for failure to
file a pre-trial brief is discretionary and should not be taken lightly. The
Court noted that while the petitioner's counsel's explanation for the late
arrival and non-filing of the pre-trial brief was not entirely convincing, the
petitioner was present in court when the case was called. The Court
highlighted the importance of allowing both parties to present their claims
fully, especially given the nature of the case involving real property. The
Court criticized the trial court for its precipitate dismissal, stating that
lesser sanctions should be considered unless a party's conduct is
egregiously negligent. The ruling underscored the principle that procedural
rules should not be rigidly applied at the expense of substantial justice,
particularly when the circumstances warrant a more lenient approach. The
Court ultimately determined that the interests of justice would be better
served by allowing the case to proceed to trial rather than dismissing it
outright.

Title
Philippine Coconut Authority vs. Corona International, Inc.
Case
G.R. No. 139910
Decision Date
Sep 29, 2000
PCA appealed CA's dismissal of its case over unpaid equipment, citing
procedural flaws. SC ruled for substantial justice, remanding the
case for proper .

Facts:
The case involves the Philippine Coconut Authority (PCA) as the petitioner
and Corona International, Inc. as the respondent. The dispute arose from a
complaint filed by Corona International against PCA for the recovery of
P9,082,221.14, which represented the unpaid balance for communication
and computer facilities sold to PCA, along with interest and damages. The
Regional Trial Court of Quezon City ruled in favor of Corona on September
10, 1996, ordering PCA to pay the claimed amount and an additional
P1,000,000 for attorney's fees. PCA contested this decision and appealed to
the Court of Appeals. However, the appellate court dismissed PCA's appeal
due to non-compliance with the requirements set forth in Section 13 of Rule
44 of the 1997 Rules on Civil Procedure, which outlines the necessary form
and contents of an appellant's brief. The dismissal was based on the
assertion that PCA's brief lacked a clear and concise statement of the case
and failed to provide adequate references to the record. PCA sought
reconsideration, but the Court of Appeals denied this request on August 25,
1999. Consequently, PCA elevated the matter to the Supreme Court,
arguing that the appellate court erred in dismissing its appeal and in
prioritizing procedural technicalities over substantial rights.

Issue:
1. Did the Court of Appeals err in ruling that the appellant's brief filed
by PCA did not comply with the requirements prescribed for its
contents?
2. Did the Court of Appeals gravely err in sacrificing substantial rights in
favor of procedural compliance?
3. Did the Court of Appeals err in dismissing PCA's appeal?

Ruling:
The Supreme Court granted PCA's petition, setting aside the resolutions of
the Court of Appeals dated October 14, 1998, and August 25, 1999. The
case was remanded to the Court of Appeals for proper disposition.

Ratio:
The Supreme Court found merit in PCA's arguments, stating that the Court
of Appeals had misapplied the standards for evaluating the sufficiency of
the appellant's brief. While acknowledging that PCA's brief did not strictly
adhere to the requirements of Rule 44, the Court emphasized that the
primary purpose of these procedural rules is to facilitate the court's
understanding of the case rather than to serve as a basis for dismissal. The
Court noted that despite the deficiencies, PCA's brief sufficiently conveyed
the essential facts and issues of the case, allowing the appellate court to
grasp the nature of the controversy. The Supreme Court underscored the
principle that technical and procedural rules should not obstruct the
attainment of substantial justice. It reiterated that deviations from strict
compliance may be permitted to ensure that justice is served, as the core
function of the judiciary is to dispense justice rather than to enforce rigid
procedural norms.
Title
Sindophil, Inc. vs. Republic
Case
G.R. No. 204594
Decision Date
Nov 7, 2018
A dispute over a Pasay City property involving fraudulent land titles; the
Supreme Court upheld nullification of titles, rejecting Sindophil's claims of
good faith and compensation.

Facts:
The case involves Sindophil, Inc. (Petitioner) and the Republic of the
Philippines (Respondent), with the decision rendered by the Supreme Court
on November 7, 2018. The dispute centers around a 2,791-square-meter
parcel of land known as the Tramo property, located on Aurora Boulevard in
Pasay City, which Sindophil currently possesses. Sindophil claims its right
to the property based on Transfer Certificate of Title (TCT) No. 132440,
issued by the Register of Deeds of Pasay City. The Republic filed a
complaint on July 27, 1993, seeking the revocation, annulment, and
cancellation of certificates of title, naming Sindophil as one of the
defendants. The Republic argued that the original TCT No. 10354, which
was issued to Marcelo R. Teodoro on November 12, 1964, was spurious and
lacked authenticity, as it was derived from a title that did not correspond to
the property in question. The Republic traced the ownership history,
indicating that Teodoro sold the property to Reynaldo Puma, who then sold
it to Lourdes Ty, who subsequently sold it to Sindophil. The Republic
contended that all titles derived from TCT No. 10354, including Sindophil's,
were null and void. In response, Sindophil and the other defendants claimed
they were innocent purchasers for value and argued that the Republic was
estopped from questioning the transfers due to its acceptance of capital
gains tax payments. The Regional Trial Court ruled in favor of the Republic,
declaring the titles null and void. Sindophil's appeal to the Court of Appeals
was dismissed for failure to file an appellants' brief on time, leading to the
current petition for review.

Issue:
1. Did the Court of Appeals err in dismissing Sindophil's appeal for
failure to file an appeal brief within the required period?
2. Did the Regional Trial Court err in deciding the case despite
Sindophil's filing of a Motion to Re-Open Case?
3. Are the certificates of title emanating from TCT No. 10354 null and
void?
4. Did the Regional Trial Court err in not awarding Sindophil
compensation from the Assurance Fund?

Ruling:
1. The Supreme Court affirmed the Court of Appeals' dismissal of
Sindophil's appeal for failure to file the required brief.
2. The Supreme Court ruled that the Regional Trial Court did not err in
deciding the case despite Sindophil's Motion to Re-Open Case.
3. The Supreme Court upheld the Regional Trial Court's finding that the
certificates of title emanating from TCT No. 10354 are null and void.
4. The Supreme Court denied Sindophil's claim for compensation from
the Assurance Fund.

Ratio:
The Supreme Court emphasized that the presumption of good faith for a
holder of a Torrens title is disputable and can be overcome by contrary
evidence. In this case, the Republic presented substantial evidence
indicating that TCT No. 10354 was void, which shifted the burden to
Sindophil to prove its good faith and the validity of its title. The Court found
that Sindophil failed to discharge this burden, as it did not present any
evidence during the trial and could not substantiate its claim of being an
innocent purchaser for value. The Court also noted that procedural rules
are essential for the orderly administration of justice, and Sindophil's failure
to file its appeal brief on time was due to its counsel's negligence, which the
Court deemed inexcusable. Furthermore, the Court ruled that the Regional
Trial Court acted within its discretion in not reopening the case, as
Sindophil's reasons for doing so were insufficient and appeared to be an
afterthought. Lastly, the Court reiterated that entitlement to compensation
from the Assurance Fund requires proof of being an innocent purchaser in
good faith, which Sindophil failed to establish.