Laza v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from an action for reconveyance filed by the petitioners seeking to annul the title of private respondent Porfirio V. Sison over Cadastral Lot 10-A or 215. The petitioners claimed ownership of this property, which was allegedly conveyed to Sison by the heirs of Agustin Gomez as payment for professional services. The petitioners had previously acquired a portion of land from Venustiano Tan, who had purchased it from the Gomez heirs, and were issued Transfer Certificate of Title No. 150270. The core dispute centers on whether the property conveyed to Sison is the same property previously sold to the petitioners. Procedural History: The Regional Trial Court (RTC), Branch 56 of San Carlos City, initially ruled in favor of the petitioners, declaring Lot 10-A or 215 as the same property sold to Venustiano Tan, voiding the conveyance to Sison, and ordering the cancellation of Sison's title. On appeal, the Court of Appeals (CA) reversed the RTC's decision, declaring Porfirio V. Sison as the rightful owner of Lot 10-A (now 215) and ordering the petitioners to respect his title, ownership, and possession, also awarding Sison P50,000.00 in attorney's fees. The CA's decision became final and executory on December 29, 1994, with an entry of judgment on January 24, 1995. The petitioners' motion for reconsideration was filed late and subsequently noted by the CA. A motion to set aside the entry of judgment and a subsequent motion to quash the writ of execution were also denied by the CA and the RTC, respectively. The Petition: The petitioners seek review on certiorari of the Court of Appeals' decision, raising three main arguments. Firstly, they contend they were denied due process due to the alleged misdelivery of the lower court's decision, which led to a belated filing of their motion for reconsideration. Secondly, they argue that the CA erroneously concluded Sison was a buyer in good faith, asserting their continuous possession of the property. Lastly, they claim the award of attorney's fees was improper as they acted in good faith in asserting their proprietary rights. The petition argues that the CA erred in noting their motion for reconsideration due to its late filing and in ruling that the subject property rightfully belonged to respondent Porfirio D. Sison.
Issue(s)
Whether the respondent Court of Appeals erred in noting the petitioners' motion for reconsideration as belatedly filed, and whether the petitioners were denied due process due to alleged misdelivery of mail regarding the lower court's decision. Whether the respondent Court of Appeals erred in ruling that the subject property rightfully belonged to private respondent Porfirio D. Sison. Whether respondent Sison was a buyer in good faith. Whether the award of attorney's fees was proper.
Ruling
The petition is denied. The Decision of the Court of Appeals dated October 20, 1994, is affirmed in toto.
Ratio Decidendi
On the timeliness of the motion for reconsideration and due process: The Court held that the rules on service by registered mail require delivery to the addressee or a person of sufficient discretion. The petitioners' claim that an 11-year-old grandson lacked sufficient discretion to receive the mail, and that the initial recipient, Leticia Ramos, was not an authorized representative, was deemed flimsy and unrealistic. The Court agreed with the CA that admitting the motion would be a prohibited second motion for reconsideration and would extend the mandatory period for filing. The perfection of an appeal within the prescribed period is jurisdictional, and non-compliance renders the judgment final and executory. The petitioners' excuse for the late filing did not constitute a valid ground to set aside the entry of judgment or grant due process. On the ownership of the property: The Court reiterated that in petitions for review on certiorari, only questions of law may be raised, not factual conclusions of the appellate court. The CA had thoroughly reviewed the records and correctly pointed out errors in the lower court's decision regarding the identity and ownership of the property. The CA's finding that Lot 10-A or 215, located in Barrio Poponto, belonged to Porfirio V. Sison, covered by TCT No. 167909, was a factual determination that the Supreme Court would not disturb in the absence of a showing that such findings were totally devoid of support or constituted a grave abuse of discretion. The petitioners' argument regarding possession was a factual matter already passed upon by the CA. On Sison's good faith: This issue was implicitly addressed in the discussion of property ownership, as the CA's finding that the property rightfully belonged to Sison implies that any claims against his ownership, including those related to good faith purchase, were rejected. On the award of attorney's fees: The CA awarded attorney's fees to Sison in the concept of damages and expenses of litigation. While the petitioners argued that no malice or bad faith could be attributed to them, the CA's award was based on the fact that Sison was declared the rightful owner and the petitioners were ordered to respect his title, ownership, and possession. The award was a consequence of the litigation and the expenses incurred by Sison in defending his ownership, which the Supreme Court found proper in affirming the CA's decision.
Main Doctrine
The perfection of an appeal within the period and in the manner prescribed by law is jurisdictional and non-compliance therewith is fatal, rendering the judgment final and executory. Furthermore, in petitions for review on certiorari, only questions of law may be raised, not factual conclusions of the appellate court, unless such findings are totally devoid of support or constitute a grave abuse of discretion.