Asis v. Heirs of Calignawan
REITERATIONFacts
The Antecedents: Spouses Cesario and Romana Engao had two children, Felipe and Angeles. Romana and Angeles were registered owners of Lot No. 581 and Lot No. 2064. Rosello Calignawan, father of respondents, claimed to have grown up with Vicente and Angeles and alleged that Angeles executed a Deed of Donation in his favor on May 25, 1984. Rosello discovered in 1988 that new transfer certificates of title were issued in the names of Felicitation, Erma, Evangeline, Cesar, and himself, facilitated by a Deed of Adjudication and a Deed of Consolidation, both dated December 2, 1982. Rosello claimed his signature on these documents was forged and that Angeles and Felipe were alive when these documents were executed, thus invalidating the adjudication of properties. Procedural History: Rosello filed a Complaint for Declaration of Nullity of Documents, Partition and Damages with Preliminary Injunction against Evangeline, Felicitation, Erma, Cesar, and Felipe. The RTC ruled that the subject properties were owned by Romana and Angeles, declared Rosello not an heir of Angeles, found the Deed of Donation invalid due to Angeles' alleged poor health and inconsistencies in signatures, and declared the Deed of Adjudication, Deed of Consolidation, and Extrajudicial Settlement void. The RTC ordered the reinstatement of original titles in the names of Romana and Angeles. On appeal, the Court of Appeals (CA) reversed the RTC, declaring the Deed of Donation valid based on res judicata from a prior case (G.R. No. 188676), while declaring the Deed of Adjudication, Deed of Consolidation, and Extrajudicial Settlement void. The CA remanded the case for partition. The Petition: Petitioners (Heirs of Engao) filed a Petition for Review before the Supreme Court, assailing the CA's decision, primarily arguing that Rosello committed forum-shopping, that the CA erred in subsuming the RTC Tacloban's decision to the RTC Burauen's decision, that respondents are estopped from challenging the RTC Tacloban's jurisdiction, and that the CA erred in admitting the respondents' belated Appellant's Brief.
Issue(s)
Whether Rosello Calignawan committed forum-shopping by filing two separate complaints before different Regional Trial Courts. Whether the Court of Appeals committed a serious legal error in ruling that Rosello did not commit forum-shopping and in admitting the respondents' belated Appellant's Brief. Whether the decision of the RTC of Burauen, which had attained finality, constitutes res judicata on the validity of the Deed of Donation in the present case. Whether the Court of Appeals committed a serious legal error in exercising unwarranted liberality and bending the rules of procedure when it admitted the respondents' Appellant's Brief despite the expiration of the time to file.
Ruling
The Supreme Court denied the petition for review and affirmed the Court of Appeals' decision in toto. The Court found that while Rosello committed forum-shopping, the issue was raised too late on appeal. The Court also upheld the CA's liberal application of procedural rules in admitting the belated Appellant's Brief due to the gross negligence of counsel, emphasizing the interest of substantial justice. Crucially, the Court ruled that the finality of the RTC of Burauen's decision constituted res judicata on the validity of the Deed of Donation, thereby affirming the CA's finding that the Deed of Donation is valid.
Ratio Decidendi
On the issue of forum-shopping: The Court acknowledged that Rosello committed forum-shopping by filing two separate complaints with similar causes of action and reliefs, seeking entitlement to the properties. However, the Court ruled that this issue was raised too late on appeal, as petitioners actively participated in the proceedings before the RTC of Burauen without raising the issue earlier. The Court reiterated that defenses not pleaded in the answer or motion to dismiss are deemed waived, except for lack of jurisdiction over the subject matter. Dismissing the case on forum-shopping would lead to contrasting final decisions from different RTCs, thus the Court opted to resolve the controversy on the merits. On the liberality of the appellate court in admitting the belated filing of Appellant's Brief: The Court upheld the CA's discretion in admitting the belated Appellant's Brief, citing gross negligence of respondents' previous counsel. The Court emphasized that while motions for extension are not granted as a matter of right, courts may relax procedural rules for good and sufficient cause or compelling reason, especially in the interest of substantial justice, fair play, and equity. The CA found the reasons proffered for the extensions, particularly the withdrawal of counsel due to negligence, to be satisfactory justifications for the relaxation of rules. On the finality of RTC of Burauen's decision constituting res judicata: The Court affirmed that the principle of res judicata, specifically by conclusiveness of judgment, was applicable. The elements were present: a final judgment by a court with jurisdiction on the merits, and an identity of issues. The RTC of Burauen's decision, which had attained finality, had already passed upon the validity of the Deed of Donation, which was a central issue in the present case. The Court stressed that any right, fact, or matter in issue directly adjudicated or necessarily involved in a determination of an action before a competent court is conclusively settled and cannot be relitigated. Furthermore, based on the principle of res judicata from the final decision of the RTC of Burauen (affirmed by the CA and this Court), the Deed of Donation was declared valid. On the validity of related documents: The CA's ruling that the Deed of Adjudication, Deed of Consolidation, and Extrajudicial Settlement were void due to involving future inheritance was upheld, as contracts on future inheritance are void under Article 1347 of the Civil Code. Consequently, the new titles and tax declarations arising from these void documents were also declared void, and the original titles in the names of Romana and Angeles were ordered reinstated.
Main Doctrine
The Court of Appeals correctly ruled that the Deed of Donation is valid, applying the principle of res judicata based on a prior final and executory decision involving the same parties and issues. Furthermore, while forum-shopping was committed, the issue was raised late on appeal and the Court opted to resolve the case on the merits in the interest of substantial justice, affirming the appellate court's liberal application of procedural rules due to gross negligence of counsel.