Landbank of the Philippines v. Abellana
REITERATIONFacts
The Antecedents: Respondent Albrando R. Abellana was the registered owner of a parcel of land. He executed a Real Estate Mortgage (REM) over this property in favor of petitioner Landbank of the Philippines to secure a loan obtained by Ernesto V. Villaos. Abellana and Villaos defaulted on their loan obligation, leading Landbank to extrajudicially foreclose the REM. Landbank emerged as the winning bidder at the public auction, and subsequently, the title to the property was consolidated in Landbank's name after the redemption period expired. Procedural History: Abellana initiated a complaint for repurchase of the property, which was dismissed by the Regional Trial Court (RTC) and affirmed by the Court of Appeals (CA). This dismissal was further upheld by the Supreme Court (SC) when Abellana filed a Petition for Review on Certiorari, which was denied and became final. Subsequently, Landbank sold the property to a third party. Abellana then filed a new case seeking the declaration of nullity of the extrajudicial foreclosure proceedings, the final deed of sale, the consolidation of ownership, and the transfer certificate of title issued to Landbank. The RTC denied Landbank's motion to dismiss but declared Abellana estopped from contesting matters connected to the repurchase case. The CA affirmed the RTC's orders. Landbank then filed the present Petition for Review on Certiorari with the SC. The Petition: Petitioner Landbank seeks to set aside the CA's decision, arguing that the CA erred in declaring that Abellana's action for nullity is not barred by prescription or laches, that res judicata and estoppel are inapplicable, and that the action is not a collateral attack on Landbank's title. Landbank also seeks a Temporary Restraining Order and/or Preliminary Injunction. The SC found the petition meritorious, ruling that Abellana is estopped from challenging the foreclosure proceedings and Landbank's ownership due to his judicial admissions in the prior repurchase case, which had become final and executory. Consequently, the SC reversed and set aside the CA's decision and resolutions, dismissing Abellana's action for lack of cause of action.
Issue(s)
Whether the present action for declaration of nullity is barred by prescription or laches. Whether the doctrines of res judicata and estoppel are applicable. Whether the present case for declaration of nullity is a collateral attack on Landbank's title. Whether Landbank is entitled to a TRO and/or writ of preliminary injunction.
Ruling
The petition is meritorious. The Court reversed and set aside the assailed Decision and Resolution of the Court of Appeals.
Ratio Decidendi
On the issue of prescription and laches: The Court held that an action for the declaration of the nullity or inexistence of a contract is imprescriptible, citing Article 1410 of the Civil Code. Even if the action were considered for reconveyance, the 10-year prescriptive period would be counted from the registration of the certificate of sale on April 29, 2004, with the redemption period ending on April 29, 2005. Since Abellana filed his complaint on November 14, 2014, it was still within the 10-year period from the earliest possible date of valid registration of Landbank's title. Therefore, prescription had not yet set in. The Court reiterated that the elements of laches must be proven positively as it is evidentiary in nature, and mere allegations in the pleadings are insufficient. Since the motion to dismiss was based solely on allegations, a determination of laches at that stage was premature. The Court emphasized that laches is a doctrine of equity and cannot be used to further oppress parties. On the issue of res judicata and estoppel: The Court found that res judicata, in both its concepts (bar by former judgment and conclusiveness of judgment), was inapplicable. There was no identity of causes of action between the repurchase case and the present declaration of nullity case. Furthermore, the issue of the validity of the foreclosure proceedings was never an issue in the repurchase case, where Abellana had already acknowledged Landbank's ownership. Therefore, there was no identity of issues for conclusiveness of judgment to apply. Despite finding res judicata inapplicable, the Court held that Abellana was estopped from challenging the validity of the foreclosure proceedings and Landbank's ownership due to his judicial admissions in the repurchase case. Abellana's admissions in his appellant's brief, acknowledging Landbank as the owner and not questioning the propriety or regularity of the foreclosure, were deemed conclusive against him. The Court noted that the CA and this Court in the previous case had already found that the foreclosure went through the required process and that Abellana failed to substantiate his right to repurchase. Consequently, Abellana had no cause of action to institute the present complaint for declaration of nullity, as it was contradictory to his prior judicial admissions. On the issue of collateral attack: Given that the issue of ownership was already settled by Abellana's judicial admissions and the prior court rulings, the Court found no actual controversy regarding the ownership or the certificate of title. Thus, the question of whether the complaint constituted a collateral attack on Landbank's title became moot and academic. On the issue of TRO/Preliminary Injunction: Since the petition was granted and the case was dismissed, the Court found no need to discuss the issuance of interlocutory orders like a TRO or preliminary injunction.
Main Doctrine
A party who judicially admits a fact cannot later challenge that fact, as judicial admissions are a waiver of proof and remove the admitted fact from the field of controversy. Such admissions are conclusive against the party making them, and all proofs to the contrary or inconsistent therewith should be ignored.