Balasbas v. Uy Realty
REITERATIONFacts
The Antecedents: Roberto L. Uy Realty and Development Corporation (Uy Realty) is the registered owner of Lot No. 555. Uy Realty discovered that several individuals, including Marilou Balasbas, et al. (Balasbas, et al.), had illegally constructed houses on its property without building permits. Despite directives from the Pasay City Mayor to vacate and dismantle their structures, Balasbas, et al. refused to comply. Procedural History: Uy Realty filed a Complaint for recovery of possession against Balasbas, et al. Balasbas, et al. claimed they had been residing on the premises for years and that their houses were on Lot No. 587, not Uy Realty's Lot No. 555, alleging Uy Realty encroached on Lot No. 587. The parties agreed that the sole issue was whether their houses stood on Uy Realty's property. A survey was conducted, and a partial judgment was rendered based on a stipulation of facts and admissions, wherein Balasbas, et al. agreed to voluntarily remove encroaching structures within 90 days. Subsequent surveys and reports confirmed encroachment. A fire destroyed case records, necessitating reconstitution. The RTC eventually rendered a Decision ordering Balasbas, et al. to vacate and pay attorney's fees. Balasbas, et al.'s Motion for New Trial was denied, and a Motion for Execution was granted. The Court of Appeals (CA) affirmed the RTC Decision, holding that the parties were bound by the partial judgment and judicial compromise, and that the survey reports were valid. The CA also ruled that the presented certification was not newly discovered evidence and Uy Realty's title could not be collaterally attacked. The Petition: Balasbas, et al. filed a Petition for Review on Certiorari, arguing that the CA erred in affirming the RTC Decision, claiming their counsel entered into a judicial compromise without their knowledge and consent, and that the survey reports were inaccurate and inconclusive. They also contended that they were ordered to vacate portions of their property even when surveys indicated their houses were not on Uy Realty's property.
Issue(s)
Whether the Court of Appeals erred in ordering the petitioners to vacate and surrender to the respondent the portion of the latter's property that the petitioners are occupying. Whether the petitioners are bound by the stipulation of facts and judicial compromise entered into by their counsel. Whether the survey reports relied upon by the RTC and CA were accurate and conclusive. Whether the petitioners are entitled to a new trial based on newly discovered evidence.
Ruling
The petition is denied for lack of merit. The Court of Appeals Decision dated January 30, 2009, and Resolution dated April 17, 2009, are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in ordering the petitioners to vacate and surrender to the respondent the portion of the latter's property that the petitioners are occupying: Based on the affirmed findings of encroachment through validly established surveys and stipulations, the Court upheld the RTC's order directing the petitioners to vacate and surrender the portions of Uy Realty's property they were occupying. The partial judgment and subsequent decisions were consistent with the evidence presented and the agreements made by the parties. On the issue of whether the petitioners are bound by the stipulation of facts and judicial compromise: The Supreme Court held that the petitioners are bound by the partial judgment dated July 9, 1987, which was rendered on the basis of a judicial compromise agreed upon by the parties. The stipulation of facts, agreed upon during the trial and affirmed by the RTC, constituted judicial admissions. To contradict these admissions, petitioners needed to show palpable mistake or that no admission was made, which they failed to do. Furthermore, the Court reiterated the well-settled rule that a client is bound by the acts, even mistakes, of their counsel, as counsel holds implied authority to manage the suit. Exceptions to this rule, such as gross negligence depriving the client of due process, were not substantiated by the petitioners. On the issue of the accuracy and conclusiveness of the survey reports: The Court found that the findings of the RTC and CA regarding petitioners' encroachment were based on surveys conducted by Engr. Abaya and Engr. De Lara. These surveys were attended and witnessed by the parties and their representatives, and their results were adopted through joint stipulations and admissions, and approved by the RTC. Therefore, it was too late for the petitioners to challenge the surveys and their joint stipulations. The CA correctly noted that the parties agreed to abide by the survey results, and by actively participating in the survey, they are barred from questioning the procedures. The Supreme Court emphasized that its jurisdiction in a Rule 45 petition is limited to pure questions of law, and it is not a trier of facts. The questions raised by the petitioners regarding the execution of the compromise agreement, the accuracy of the survey reports, and the declaration of encroachment required a re-evaluation of factual findings, which is generally outside the Court's purview under Rule 45. Even if the Court relaxed this rule, the merits of the petition were insufficient to reverse the lower courts' decisions. On the issue of whether the petitioners are entitled to a new trial based on newly discovered evidence: The Court affirmed the CA's ruling that the certification presented by the petitioners was not newly discovered evidence that would warrant a new trial. The petitioners failed to demonstrate that this evidence could not have been discovered and presented during the trial despite the exercise of due diligence. Moreover, the Court noted that Uy Realty's title could not be attacked collaterally in this case.
Main Doctrine
A party who actively participated in the conduct of a survey and agreed to abide by its results through stipulations and admissions is barred from questioning the survey and its findings. Furthermore, a client is bound by the acts of their counsel, absent proof of gross negligence or fraud that deprives the client of due process.