Aron v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Ramon P. Aron filed a Complaint for Specific Performance, Annulment of Contract and Title, Reconveyance and Damages against Paciencia Perrin and other defendants. Petitioner alleged that on April 3, 1963, he entered into a Contract to Sell with Perrin for a 35,718 square meter parcel of land for P25,000.00, payable in installments over fifteen years, with the last installment due on April 3, 1983. Upon full payment, Perrin was obligated to execute a Deed of Absolute Sale and deliver title. Petitioner claimed he made the last installment payment on April 3, 1983, but Perrin failed to comply with her obligations. He later discovered that Perrin had authorized Jose M. Dragon to sell the property to Doña Juana Development, Inc. as early as September 1972, and that Dragon, Perrin's attorney-in-fact, was also the President of Doña Juana. Petitioner also alleged that subsequent sales of lots within the property to other defendants were done in disregard of his rights. He prayed for specific performance, annulment of sales and titles, reconveyance, moral and exemplary damages, and attorney's fees. Procedural History: On September 17, 1993, some defendants (Narciso and Victoria Saliba, Erlinda Guyamin, and Leonila Pagkaliwanagan) filed a Motion to Dismiss on grounds of lack of cause of action and prescription. On September 30, 1993, other defendants (Diosdada and Ester Castillo, Marieta Vasquez, Andres F. Nieto, and Ameurfina Macapagal) also moved for dismissal based on prescription and laches, which Soledad Magpoc adopted. Meanwhile, defendants Magdalena C. Rivera and Natividad Encarnacion submitted an Answer with Counterclaim, asserting good faith as purchasers and praying for dismissal of the complaint against them. On July 14, 1994, the Regional Trial Court (RTC) granted the motions to dismiss, ruling that the movants were innocent purchasers for value. On August 26, 1996, the Court of Appeals (CA) affirmed the RTC's order. Petitioner filed a motion for reconsideration on September 16, 1996. On October 29, 1996, the CA expunged the motion for reconsideration from the records for having been filed late. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, assailing the CA's decision and its order expunging his motion for reconsideration.
Issue(s)
Whether the Court of Appeals' decision has become final due to the late filing of the petitioner's motion for reconsideration. Whether prescription has set in, barring the petitioner's cause of action, and the rights of subsequent purchasers.
Ruling
The petition is dismissed. The Court affirmed the Court of Appeals' decision that the case has become final and executory because the petitioner's motion for reconsideration was filed out of time. The Court also ruled that the petitioner's action has prescribed.
Ratio Decidendi
On the issue of the finality of the Court of Appeals' decision: The Court found that the petitioner's motion for reconsideration was indeed filed out of time. The petitioner received notice of the CA's decision on August 29, 1996. The reglementary period to file a motion for reconsideration is fifteen (15) days from notice. However, the petitioner filed his motion only on September 16, 1996, which is beyond the prescribed period. Consequently, the CA correctly ordered the motion expunged from the records. As a result, the decision of the Court of Appeals became final and executory. On the issue of prescription and the rights of subsequent purchasers: The Court held that the petitioner's action has prescribed. The petitioner's cause of action is based on a written contract, specifically a contract to sell a parcel of land. Under Article 1144 of the Civil Code of the Philippines, an action based upon a written contract must be brought within ten (10) years from the time the right of action accrues. The petitioner's complaint alleged that the last installment payment was due on April 3, 1983. Under the contract, upon full payment, the seller was obliged to execute a deed of absolute sale. Therefore, the petitioner's right of action accrued on April 3, 1983. The petitioner filed his complaint on July 23, 1993, which is more than ten (10) years after the cause of action accrued. Thus, the action has prescribed. The Court also noted that the contract to sell between the petitioner and Perrin was not registered or annotated on the Transfer Certificate of Title. Consequently, the subsequent respondents were considered purchasers in good faith and for value. As such, the petitioner has no cause of action against them for reconveyance.
Main Doctrine
An action for specific performance, annulment of contract, and reconveyance based on a written contract to sell prescribes within ten (10) years from the time the right of action accrues. Furthermore, a decision of the Court of Appeals becomes final and executory if a motion for reconsideration is filed out of time.