Baggenstos v. Court of Appeals
REITERATIONFacts
The Antecedents: Josefino de Guzman filed a complaint against Eliza Francisco Baggenstos for an unpaid balance of ₱85,000.00 for house renovation. Baggenstos was declared in default for failure to file an answer, and the Regional Trial Court (RTC) rendered judgment in favor of De Guzman. A writ of execution was issued, and a parcel of land registered under Baggenstos' name (TCT No. 171720) was levied and sold at public auction to Pacifico Magno, Jr. as the highest bidder. After the redemption period lapsed, an Officer's Deed of Sale was executed in Magno's favor. Procedural History: Magno filed a petition to compel the surrender of the duplicate certificate of title and for the issuance of a writ of possession. Baggenstos opposed, claiming the default judgment was void due to improper service of summons. The RTC granted Magno's petition, ordering Baggenstos to surrender the title and issuing a writ of possession. A notice to vacate was issued. Baggenstos filed a manifestation claiming the sheriff was attempting to enforce the orders against her other lot (TCT No. 96923) where her house stands, instead of the vacant lot (TCT No. 171720) that was sold. The RTC issued a break-open order. Subsequently, the RTC amended its order to clarify that the execution proceedings should be enforced against TCT No. 171720. The Court of Appeals (CA) denied due course and dismissed Baggenstos' Petition for Annulment of Judgments, Orders and Writs with Damages, finding it insufficient in form and substance. The Petition: Baggenstos filed a petition for review on certiorari with the Supreme Court, assailing the CA's resolution dismissing her petition for annulment.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for annulment for insufficiency in form and substance. Whether the questioned orders of the trial court were void insofar as the lot covered by TCT No. 96923 was concerned, as it was not the property sold by the sheriff. Whether the questioned orders and execution proceedings against the property covered by TCT No. 96923 should be annulled.
Ruling
The Supreme Court dismissed the petition for being moot. The Court held that the issues raised by Baggenstos had become moot and academic because the execution proceedings had been completed, the lot covered by TCT No. 171720 had been fully paid for by Magno, and a new title had been issued in his name. Baggenstos' other lot (TCT No. 96923) was no longer subject to any coercive writ arising from the original judgment. Therefore, the assailed resolution of the Court of Appeals had become inconsequential, and Baggenstos was no longer entitled to any actual and substantial relief.
Ratio Decidendi
On the issue of the Court of Appeals dismissing the petition for annulment for insufficiency in form and substance: The Supreme Court affirmed the CA's dismissal, noting that Baggenstos' petition suffered from procedural defects, including the lack of an affidavit of merit and the improper signing of the certificate of non-forum shopping. Furthermore, the CA correctly pointed out that Baggenstos was not truly seeking to annul the default judgment but rather the processes in the implementation of a writ of execution for a final and executory judgment. The CA also correctly stated that errors committed in the course of execution proceedings are generally corrected by appeal or special civil actions, not by a petition for annulment of judgment. On the issue of whether the questioned orders were void concerning TCT No. 96923: The Supreme Court found this issue moot. While Baggenstos claimed the sheriff attempted to enforce the writ against her lot with a house (TCT No. 96923) instead of the vacant lot sold (TCT No. 171720), the subsequent events rendered this dispute inconsequential. The parties agreed, and the trial court amended its order, to enforce the writs on the correct lot (TCT No. 171720). The subsequent transfer of TCT No. 171720 to Magno meant that Baggenstos' other property was no longer at risk from the original judgment. On the issue of annulling the questioned orders and execution proceedings against TCT No. 96923: The Supreme Court dismissed this issue as moot. The core of Baggenstos' concern was to protect her property covered by TCT No. 96923 from execution. However, the execution proceedings were completed with the sale of TCT No. 171720, which fully satisfied the judgment. The transfer of TCT No. 171720 to Magno and the issuance of a new title in his name meant that Baggenstos' other property was no longer subject to any further action related to the original debt. Thus, there was no longer a justiciable controversy regarding TCT No. 96923 in relation to the satisfied judgment.
Main Doctrine
A petition for annulment of judgments, orders, and writs, filed after the execution proceedings have been completed and the property in question has been transferred to a third-party purchaser, is rendered moot and academic, as the relief sought can no longer be granted.