Escaler v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Spouses Jose L. Reynoso and Africa V. Reynoso sold a parcel of land in Antipolo, Rizal, to petitioners Maria Luisa de Leon Escaler and Ernesto Escaler, and Cecilia J. Roxas and Pedro Roxas, on March 7, 1958. The Deed of Sale included a warranty against eviction, wherein the vendors guaranteed valid title and ownership and promised to defend the property against all claims. Subsequently, on April 21, 1961, the Register of Deeds of Rizal and A. Doronilla Resources Development, Inc. filed a case seeking the cancellation of the original title of Angelina C. Reynoso, the predecessor-in-interest of the vendors, alleging it was a duplicate registration. Petitioners, as vendees, opposed this petition. 2. Procedural History: An order was issued on June 10, 1964, in the cancellation case, setting aside the original decree and directing the cancellation of the original title and all subsequent transfer certificates of title, including those of the petitioners, deeming them null and void. On August 31, 1965, the petitioners filed Civil Case No. 9014 against the vendors for breach of warranty against eviction, seeking recovery of the property's value and damages, asserting that the order in the cancellation case had become final and had resulted in their loss of the property. The trial court granted a summary judgment in favor of the petitioners. The private respondents appealed this decision to the Court of Appeals, assigning as error the trial court's finding that they had been summoned and given their day in court in the cancellation case. 3. The Petition: The Court of Appeals reversed the trial court's decision, dismissing the case and ruling that the petitioners had failed to formally notify the vendors of the eviction suit as required by Articles 1558 and 1559 of the New Civil Code. The petitioners are now before the Supreme Court via a Petition for Review on Certiorari, arguing that the Court of Appeals erred in strictly applying Articles 1558 and 1559 and that the case should have been affirmed or remanded. The Supreme Court, however, found the petition to be without merit, emphasizing that the vendors were not summoned in the eviction suit at the instance of the vendees, as required by law, and that merely furnishing a copy of the opposition filed in the cancellation case did not constitute proper notice.
Issue(s)
Whether the Court of Appeals erred in strictly applying Articles 1558 and 1559 of the New Civil Code regarding the requirement of summoning the vendor in an eviction suit. Whether the Court of Appeals erred in reversing the trial court's decision, considering the procedural flaw, and whether remanding the case for a hearing on the merits was necessary.
Ruling
The petition is devoid of merit and is hereby dismissed. The appealed decision of the then Court of Appeals is affirmed.
Ratio Decidendi
On the application of Articles 1558 and 1559 of the New Civil Code: The Court held that the fourth requisite for enforcing a vendor's liability for eviction, namely, that the vendor must be summoned in the suit for eviction at the instance of the vendee, was not present in this case. The petitioners' act of furnishing the respondents with a copy of the opposition they filed in Case No. 4252 via registered mail does not constitute the formal notice required by law. Articles 1558 and 1559 of the New Civil Code explicitly require that the vendor be summoned in the suit for eviction at the instance of the vendee, which means the vendor should be made a party to the suit, either as a co-defendant or through a third-party complaint. The Court emphasized that this procedural requirement is crucial for the vendor to be able to defend their title and the validity of the sale. On the reversal of the trial court's decision and failure to remand: Since the essential requirement of summoning the vendor in the eviction suit was not met, the vendor's liability for eviction could not be enforced. Consequently, the trial court erred in granting the summary judgment based on the violation of the warranty against eviction without this crucial procedural step having been taken by the vendees. The Court of Appeals correctly identified this deficiency and, therefore, its reversal of the trial court's decision was proper. The case did not need to be remanded for further hearing on the merits because the absence of the required notice was a fatal procedural flaw that precluded the enforcement of the warranty against eviction.
Main Doctrine
For a vendor's liability for eviction to be enforced, the vendee must formally summon the vendor as a co-defendant or file a third-party complaint against them in the suit for eviction, as mere furnishing of a copy of an opposition filed in a related case does not constitute the required notice.