Sia v. Heirs of Mariano
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership and right of redemption of several parcels of land originally owned by spouses Macario and Irene Mariano. Following Macario's death, an extra-judicial settlement was executed, leading to new titles in the names of Irene, Jose P. Mariano, and Erlinda Mariano-Villanueva. Irene later executed an Affidavit of Merger consolidating ownership under her name. Subsequently, Irene executed Deeds of Absolute Sale for several lots to Raul Santos, and Lot 612 was sold to Greta Tinga de los Reyes, who later sold it to Bonifacio Sia, Jr. Lot 15-C, under TCT No. 7261, was levied upon in favor of Francisco Bautista and subsequently sold at public auction to Ruben Sia, who was issued TCT No. 20201. Procedural History: After Irene's death, Jose and Erlinda filed a complaint for annulment of sale with damages against Rolando, Raul, and the Register of Deeds, seeking to annul the April 15, 1975 Deed of Absolute Sale due to forgery and simulated sale. Following Jose's death, his heirs substituted him. Later, the Heirs of Jose and the Testate Estate of Irene filed another complaint for annulment of title and deed with damages against Raul, the Heirs of Rolando, and the Register of Deeds, seeking to annul the March 10, 1982 Deed of Absolute Sale for being fictitious. These two cases were consolidated. The trial court rendered a Joint Judgment dismissing the complaints and counterclaims, upholding the validity of Irene's sales to Raul. On appeal, the Court of Appeals (CA) declared the Deeds of Absolute Sale dated April 15, 1975, and March 10, 1982, and the Deed of Sale with Real Estate Mortgage dated August 9, 1990, as null and void, ordering the cancellation of titles in the names of Raul Santos and Amado Sanao, and the issuance of new titles in the name of the heirs of Irene P. Mariano. The CA also ordered the defendants-appellees to pay moral damages and attorney's fees. A Motion for Reconsideration was filed by Raul, and the Heirs of Jose and Erlinda filed a Motion for Partial Reconsideration/Clarification regarding Lot 15-C. On May 19, 2000, the CA denied the motions for reconsideration but granted the Supplemental Motion to Restore Possession and Administration, declaring that the Heirs of Jose P. Mariano and Erlinda Mariano Villanueva have the right to redeem Lot 15-C from Ruben Sia. The Petition: Petitioner Ruben S. Sia filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Resolution dated May 19, 2000. Sia argues that the CA erred in declaring that the respondents have the right to redeem Lot 15-C because this issue was not raised in the trial court or on appeal, and was only introduced for the first time in the respondents' Motion for Partial Reconsideration/Clarification. He further contends that Lot 15-C was not a subject of the appeal, as the CA itself limited the appeal to four parcels of land. Additionally, Sia claims he was not impleaded as a party in the case and therefore cannot be bound by the judgment. Respondents counter that this Court's decisions in G.R. Nos. 94617 and 95281, which declared their right to redeem Lot 15-C, render the present petition moot and academic. They also argue that the issue of redemption was raised in the appellee's brief and that Sia was aware of the pendency of the case due to a notice of lis pendens.
Issue(s)
Whether the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C from petitioner when the redemption of Lot 15-C was not raised as an issue, not made the subject of an assignment of error, not closely related to any issue, nor otherwise treated in the parties' briefs before the appellate court; and whether there was an actual case or controversy regarding the redemption of Lot 15-C given the prior Supreme Court decision in G.R. Nos. 94617 and 95281. Whether the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C when Lot 15-C was not a subject matter of the appeal before the CA. Whether the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C when petitioner, the current holder of the title to Lot 15-C, was not impleaded as a party in the case before the CA; and on the procedural limitations of the CA in addressing issues not properly raised on appeal.
Ruling
The petition is GRANTED. The portion of the Court of Appeals’ Resolution dated May 19, 2000, declaring that plaintiffs-appellants have the right to redeem Lot 15-C from Ruben Sia, is DELETED, subject to the final decision in G.R. Nos. 94617 and 95281.
Ratio Decidendi
On the propriety of the CA's declaration regarding the right to redeem Lot 15-C and the existence of an actual case or controversy: The Supreme Court held that the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C from petitioner Ruben Sia. The Court emphasized that Lot 15-C was not a subject matter of the appeal before the CA. Furthermore, petitioner Ruben Sia, who held the title to Lot 15-C at the time of the CA's resolution, was not impleaded as a party in the case before the trial court or the CA. The Supreme Court found that there was no longer an actual case or controversy between the parties concerning the issue of redemption of Lot 15-C because the Supreme Court itself had already rendered a final decision in G.R. Nos. 94617 and 95281, which involved both petitioner Sia and respondent Erlinda Villanueva, declaring that respondents have the right to redeem the lot covered by TCT No. 17745, which refers to Lot 15-C. On Lot 15-C not being a subject matter of the appeal: The Supreme Court held that the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C when Lot 15-C was not a subject matter of the appeal before the CA, as the CA itself explicitly stated that only four lots were involved in the appeal. On the lack of impleadment of the petitioner and the procedural limitations of the CA: The Supreme Court held that the Court of Appeals erred in declaring that respondents have the right to redeem Lot 15-C when petitioner, the current holder of the title to Lot 15-C, was not impleaded as a party in the case before the CA. The Supreme Court reiterated that appellate courts are generally limited to passing upon the errors assigned or intended to be raised in the appeal. The declaration by the CA regarding the right to redeem Lot 15-C was made in a resolution denying a motion for reconsideration, and it pertained to an issue that was not raised in the original appeal, nor was it part of the assigned errors. Therefore, the CA exceeded its jurisdiction by making a pronouncement on the redemption of Lot 15-C, especially when the petitioner, who was directly affected, was not a party to the case.
Main Doctrine
A declaration by an appellate court regarding the right to redeem a property not included in the appeal and affecting a party not impleaded in the original case is improper and may be deleted, especially when a final decision on the matter has already been rendered by the Supreme Court.