Guinobatan Historical and Cultural Association v. Court of First Instance of Albay

G.R. No. L-52295 · 1990-02-15 · J. PARAS, J.: · Primary: Civil; Secondary: Civil

REITERATION

Facts

1. The Antecedents: The underlying dispute concerns a 167-square-meter portion of Lot 375. Private respondents, spouses Adolfo Morato and Esperanza Navarro, purchased this portion from the Roman Catholic Bishop of Legazpi, Inc. When the private respondents filed a petition with the respondent court to segregate this portion, issue a title, and annotate the sale, the petitioner, Guinobatan Historical and Cultural Association (GHACA), opposed the petition. GHACA argued that the property was part of a registered historical landmark of Albay and that the deed of sale was not validly executed. 2. Procedural History: The private respondents filed a petition with the Court of First Instance of Albay, Branch IV, for the segregation of Lot 375, issuance of title, and annotation of their sale. GHACA opposed this petition. The respondent court, in an Order dated June 6, 1979, granted the private respondents' petition, ordering the Register of Deeds to segregate the specified area, annotate the sale, cancel the existing title, and issue a new one in the name of the private respondents. GHACA's subsequent motion for reconsideration was denied by the same court in an Order dated October 23, 1979. 3. The Petition: This case comes before the Supreme Court via a petition for review on certiorari, challenging the June 6, 1979, and October 23, 1979, Orders of the Court of First Instance of Albay. Petitioners raise several issues, including violations of judicial stability and res judicata due to a prior similar petition, disregard of constitutional provisions and presidential decrees regarding the preservation of cultural properties, the indisposable nature of the property as a registered cultural property, and the alleged nullity of the deed of sale because the original title was in the name of a different entity. a different entity. corporate entity. corporation. corporate entity. corporation. corporate entity. corporation. corporate entity. entity. entity. different entity different from the seller. Petitioners argue that the respondent court's orders were issued in disobedience to relevant laws and that the property is not within the commerce of man.

Issue(s)

Whether the respondent court's orders violated judicial stability and res judicata. Whether the respondent court disregarded laws on the preservation of cultural properties, and whether the portion of Lot 375 is indisposable as registered cultural property. Whether the respondent court disobeyed Presidential Decree No. 1081. Whether Lot 1 (2) of RO 18298, with a lien of GHACA, is outside the commerce of man. Whether the New Constitution and Presidential Decrees impose limitations on the disposition and sale of the property as registered cultural property. Whether expropriation is a proper remedy for GHACA. Whether the respondent court resolved the issue of GHACA's creation under RA 4368 and RA 4846. Whether the Deed of Absolute Sale is null and void because the registered owner is different from the vendor.

Ruling

The Supreme Court dismissed the petition for review on certiorari, finding it devoid of merit. The Court affirmed the orders of the Court of First Instance of Albay.

Ratio Decidendi

On the contention of violation of judicial stability and res judicata: The Court found this contention untenable. It agreed with the private respondents' argument that the previous case (RT 1619) and the present case involved different causes of action and different sets of parties. RT 1619 concerned a petition by the Roman Catholic Bishop of Legazpi, Inc. for reconsideration of a certificate of title and a request by another buyer, Amado Ecal, for annotation of his interest, which was denied because his interest was not reflected on the title at the time of its loss. The present case, however, deals with the annotation of a deed of absolute sale to a different set of buyers. On the alleged violation of the Constitution and laws on cultural preservation: The Court found that the claim that the property was a registered historical landmark was rebutted by evidence from the National Historical Institute (NHI). A letter from the NHI indicated that their records did not show the ruins as a national landmark. Furthermore, even if registered, the Court noted that the mere registration of a property as a historical landmark is doubtful to deprive the owner of the right to dispose of it. The Court cited Article III, Section 1 of the Constitution and Article 435 of the Civil Code, which clearly state that no person shall be deprived of property except by competent authority, for public use, and upon payment of just compensation. Therefore, the sale did not violate these provisions. No corresponding ratio provided in the source text. No corresponding ratio provided in the source text. No corresponding ratio provided in the source text. No corresponding ratio provided in the source text. No corresponding ratio provided in the source text. On the contention that the Deed of Absolute Sale is void ab initio: The Court deemed this issue as improperly raised for the first time in the petition. It reiterated the well-settled rule that, except for questions of jurisdiction, no question will be entertained on appeal unless it has been raised in the court below and is within the issues made by the parties in their pleadings. Even if the issue were to be entertained, the Court held that petitioners were not the proper parties to question the validity of the sale. The proper party to question the sale would be the claimed registered owner, the Corporacion Franciscana de la Provincia de San Gregorio Magno de Filipinas, as it is the entity that stands to be benefited or injured by the judgment. This aligns with the principle that the real party in interest is the one who stands to be benefited or injured by the judgment or is entitled to the avails of the suit.

Main Doctrine

The mere registration of a property as a historical landmark does not automatically deprive the owner of the right to dispose of it, as deprivation of property requires competent authority, public use, and just compensation. Furthermore, a party not directly affected by a contract cannot question its validity.