Basbas v. Sayson
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a parcel of agricultural land in Leyte. In 1976, respondents Beata and Roberto Sayson, Sr. filed a petition to register this land. The petition was opposed by Eugenio Basbas, Teofilo Aras, and Rufino Aras. In 1979, the Court of First Instance (CFI) ruled in favor of the Saysons, adjudicating the land to them. This decision was affirmed by the Court of Appeals (CA) in 1985, becoming final and executory. A Writ of Possession was issued in 1985 but remained unimplemented. An Alias Writ of Possession was issued in 1989, but Eugenio Basbas, Sr. and Eugenio Basbas, Jr. refused to vacate, demanding a relocation survey. A subsequent court order in 1989 directed the original oppositors and other named individuals to vacate the property as defined by a Commissioner's Report, warning of contempt. 2. Procedural History: The 1989 order to vacate was not implemented within the five-year period. Consequently, in 1995, the respondents filed a Complaint for Revival of Judgment before the Regional Trial Court (RTC) of Ormoc City, impleading the original oppositors and others, including spouses Pablito and Marcelina Basarte, who allegedly harvested coconuts from the property. Several petitioners filed a Motion to Dismiss, which was denied. They then filed an Answer with Counterclaim, admitting most of the complaint's allegations regarding the prior judgments and orders but denying that they were all original oppositors and asserting ownership/possession rights. After procedural steps including service of alias summons and adoption of pleadings by other parties, the RTC, on May 21, 2001, rendered a judgment on the pleadings and/or summary judgment, ordering the revival of the CA decision and the 1989 RTC order, and directing the issuance of a Writ of Possession. The petitioners appealed this decision to the Court of Appeals. 3. The Petition: The Court of Appeals, in a decision dated February 17, 2004, affirmed the RTC's ruling, finding no reversible error. The CA held that the petitioners' Answer admitted most of the complaint's allegations, thus justifying the judgment on the pleadings/summary judgment. The CA also found that the petitioners' refusal to vacate supported the respondents' cause of action and that the September 13, 1989 order was a final order. The CA further upheld the validity of the Special Power of Attorney (SPA) executed by Beata Sayson in favor of her son, Roberto Sayson, Jr. Petitioners' motion for reconsideration was denied. They now seek review by this Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that a judgment on the pleadings/summary judgment was improper due to genuine issues of fact, that the complaint failed to state a cause of action, that the wrong judgment was ordered revived, and that the SPA was invalid, rendering Beata Sayson improperly represented.
Issue(s)
Whether the Court of Appeals committed serious errors of law in affirming the Regional Trial Court's Order granting respondents' motion for judgment on the pleadings and/or summary judgment. Whether the Court of Appeals committed serious errors of law in affirming the Regional Trial Court's Order and declaring that the petitioners' argument that respondents' complaint failed to state a cause of action has no merit. Whether the Court of Appeals committed serious errors of law in affirming the Regional Trial Court's Order which ordered the revival of the Judgment of the Court of Appeals in CA-G.R. No. 66541, despite this not being the judgment sought to be revived in Civil Case No. 3312-0. Whether the Court of Appeals committed serious errors of law in ruling that the duly notarized Special Power of Attorney in favor of Roberto Sayson, Jr. is valid and that he is authorized to represent his mother, Beata Sayson.
Ruling
The Petition for Review on Certiorari is DENIED, and the assailed Decision of the Court of Appeals dated February 17, 2004, and Resolution dated April 19, 2006, in CA-G.R. CV No. 72385 are AFFIRMED.
Ratio Decidendi
On the propriety of summary judgment: The Court held that the instant case was proper for summary judgment. While petitioners' Answer raised affirmative defenses, these defenses concerning the propriety of the action for revival of judgment and the proper parties were not genuine issues requiring presentation of evidence. The Court found that these issues could be resolved by examining the pleadings and pertinent court records, making a full-blown trial unnecessary and a waste of time and resources. The Court distinguished summary judgment from judgment on the pleadings, noting that summary judgment is appropriate when issues exist but are not genuine, as opposed to judgment on the pleadings where no ostensible issue is raised. On whether the complaint states a cause of action: The Court agreed with the respondents that the complaint sufficiently stated a cause of action for revival of judgment. The complaint, read in its proper context, sought the enforcement of the executory decision of the Court of Appeals and the subsequent orders ancillary thereto, including the September 13, 1989 Order. The Court reiterated that under Section 6, Rule 39 of the Rules of Court, a judgment that has not been enforced within five years may be enforced by an action. The September 13, 1989 Order was considered part of the process to enforce the judgment. On the revival of the CA Decision: The Court found that the respondents' prayer in their complaint, when taken in context, implicitly sought the implementation of the CA Decision dated July 24, 1985, and the orders ancillary to it. The RTC's Order of May 9, 1997, was quoted with approval, stating that the complaint invoked and sought to implement the executory decision of the CA, not solely the RTC's order. Therefore, the revival of the CA decision was consistent with the overall prayer for enforcement. On the validity of the Special Power of Attorney (SPA): The Court ruled that any perceived defect in the SPA would not serve to bar the case from proceeding. It reasoned that Roberto Jr., as a co-owner of the subject property by succession from his father, could bring an action for the recovery of the co-owned property without the necessity of joining all other co-owners. Although the action was for revival of judgment, the underlying purpose was to implement the order to vacate and ultimately recover possession. Therefore, Roberto Jr. could prosecute the case alone on behalf of himself and his co-owner, Beata, making the issue of the SPA's validity moot.
Main Doctrine
A summary judgment is proper when, although issues appear to exist in the pleadings, these issues are not genuine and can be resolved based on the pleadings and supporting documents without the need for a full trial. Furthermore, a co-owner may bring an action for the recovery of co-owned property without joining all other co-owners, as the suit is presumed to be for their benefit.