Sta. Romana v. Imperio
REITERATIONFacts
The Antecedents: Silvio R. Viola (Principal) executed a power of attorney in favor of his brother, Dr. Jose R. Viola (Agent), to manage and sell seven parcels of registered land. The Agent, on behalf of the Principal, entered into an installment sale agreement with Pablo Ignacio for six lots covered by Transfer Certificate of Title (TCT) No. 19556. This agreement was annotated on the TCT. Subsequently, the Principal sold a larger land area, including Lot No. 622 (part of TCT No. 19556), to Diosdado Sta. Romana (appellant). Sta. Romana then sold the same land to Carlos Imperio (appellee), in whose name TCT No. 28946 was issued after cancellation. Imperio subsequently sold portions of the land to several occupants who were previously lessees. Procedural History: Pablo Ignacio filed a complaint against the occupants, appellee, appellant, and the Principal to annul the sales and recover possession. The lower court ruled in favor of Ignacio, ordering the Principal to execute a deed of sale, directing the cancellation of titles, and ordering the appellee to refund the occupants. The Court of Appeals affirmed this decision but, upon appellee's motion for reconsideration, amended its decision to order the appellant (Sta. Romana) to reimburse the appellee (Imperio) the sum of P8,463.00, representing the aggregate amount Imperio had to refund to the occupants. Appellant sought review of this amended decision. The Appeal: Appellant Diosdado Sta. Romana appealed the amended decision of the Court of Appeals, arguing that the appellate court erred in taking cognizance of the case due to jurisdictional limits, in amending its decision without affording him a chance to answer the motion for reconsideration, and in ordering reimbursement despite the appellee being in pari delicto. He contended that the appellate court's jurisdiction was exceeded by the amount sought in the cross-claim and that the amended decision was issued without due process.
Issue(s)
Whether the Court of Appeals erred in taking cognizance of the case given the amount involved. Whether the Court of Appeals erred in amending its decision without giving the appellant an opportunity to file an answer to the motion for reconsideration. Whether the appellee is entitled to reimbursement from the appellant despite allegedly being in pari delicto.
Ruling
The Supreme Court affirmed the amended decision of the Court of Appeals, ordering appellant Diosdado Sta. Romana to reimburse appellee Carlos Imperio the sum of P8,463.00. The Court found no error in the appellate court's jurisdiction, its amendment of the decision, or in ordering the reimbursement, as the principle of pari delicto was not applicable to the contract between appellant and appellee, which was governed by the law on sales and warranty against eviction.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of Appeals did not err in taking cognizance of the case. It noted that Republic Act No. 2613, enacted on August 1, 1959, increased the appellate jurisdiction of the Court of Appeals from P50,000 to P200,000. Since the case involved claims exceeding P50,000 but not P200,000, the Court of Appeals had the proper jurisdiction to hear the appeal after the law's enactment. The Court cited its practice of remanding cases to the Court of Appeals that were previously forwarded to the Supreme Court due to the old jurisdictional limit, demonstrating adherence to the amended law. On Issue 2: The Supreme Court found no merit in the appellant's claim that the Court of Appeals erred in amending its decision without giving him a chance to answer the motion for reconsideration. The Court pointed out that the appellant was allowed to and did file a printed motion for reconsideration, which was extensive and addressed the merits of the appellee's motion. After due consideration, the Court of Appeals denied the motion for reconsideration. Therefore, the demands of substantial justice were deemed satisfied, and the appellant was not deprived of due process. On Issue 3: The Supreme Court ruled that the appellee is entitled to reimbursement from the appellant, and the principle of pari delicto is not applicable to their contract. While the appellee did not file a cross-claim against the appellant, the occupants had filed a cross-claim against both. Upon paying the occupants, the appellee became subrogated to their rights against the appellant. Moreover, the Court invoked the elementary principle of law that a vendor warrants his title, and in case of eviction, the vendee is entitled to the return of the value of the thing sold at the time of eviction. The contract between appellant and appellee was a valid contract of sale governed by the law on sales and double sales, not a void contract under Article 1412 of the Civil Code, thus precluding the application of pari delicto.
Main Doctrine
The case reiterates the principles governing double sales of immovable property under Article 1544 of the Civil Code, emphasizing that ownership vests in the buyer who first registers the sale in good faith. In the absence of registration, possession in good faith determines ownership, and if neither is present, the buyer with the oldest title prevails. The Court also affirmed the vendor's warranty against eviction under Articles 1495, 1547, and 1555, entitling the vendee to recover the value of the property at the time of eviction.