Torres v. Republic
REITERATIONFacts
The Antecedents: The Republic of the Philippines initiated a Complaint for Cancellation of Titles against Spouses Leonora and Florencio Gaspar, and the Register of Deeds of Davao City, to nullify free patents and original certificates of title (OCTs) issued to the Spouses Gaspar and revert the properties to the government. The Regional Trial Court (RTC) Branch 8 determined that the free patent applications were fraudulent and misrepresented, consequently ordering the cancellation of the titles and reversion of the lots. This decision was upheld by the Court of Appeals (CA), and the Supreme Court subsequently denied Leonora Gaspar's petition for review on certiorari. Procedural History: During the execution phase of the original judgment, the Republic requested the cancellation of all titles derived from the invalidated free patents and OCTs. The RTC Branch 8 acceded to this motion, mandating the cancellation of several Transfer Certificates of Title (TCTs), including those registered under the names of petitioners Ma. Luisa Annabelle A. Torres, Rodolfo A. Torres, Jr., and Richard A. Torres. The petitioners then filed a petition for annulment of judgment with the CA, asserting a lack of jurisdiction and a violation of due process because they were not original parties to the case. The CA dismissed this petition, ruling that the RTC Order was issued during the execution stage and did not constitute a final judgment as defined under Rule 47. The CA also applied the doctrine of stare decisis, referencing a prior case with identical issues and the order being challenged. The Petition: Petitioners are seeking a review of the CA's dismissal of their petition for annulment of the RTC Order, arguing that the CA erred in its decision and in its application of stare decisis. They maintain that the cancellation of their derivative titles was effected without jurisdiction and due process, and that they were bona fide purchasers. Furthermore, they contend that they are entitled to avail of annulment of judgment because the RTC Order modified the judgment intended for enforcement and because ordinary legal remedies were not available to them.
Issue(s)
Whether the CA erred in dismissing the petition for annulment of the RTC Order dated June 30, 2015, and whether the RTC Order dated June 30, 2015, which ordered the cancellation of derivative titles, is a judgment, final order, or resolution contemplated under Rule 47 of the Rules of Court. Whether the RTC Order dated June 30, 2015, was issued with jurisdiction and with due process. Whether the doctrine of stare decisis was correctly applied by the CA. Whether there was substantial compliance with the requirements for verification and certification against forum shopping.
Ruling
The petition is denied. The Resolutions dated July 27, 2018, and April 30, 2019, of the Court of Appeals in CA-G.R. SP No. 08294-MIN are affirmed.
Ratio Decidendi
On the nature of the assailed RTC Order: The Court held that the RTC Order dated June 30, 2015, was issued during the execution stage of a final and executory decision. It was an order to carry out the enforcement of the RTC's April 20, 1999 Decision, specifically ordering the reversion of the subject lots to the government. Such an order is not a judgment, final order, or resolution contemplated under Rule 47 of the Rules of Court, which governs annulment of judgments. Therefore, a petition for annulment of judgment under Rule 47 is not the proper remedy. The Court affirmed the CA's finding that the RTC Order was issued by virtue of the RTC's residual authority under Section 6, Rule 135 of the Rules of Court. This residual authority allows courts to issue all auxiliary writs, processes, and other means necessary to carry its jurisdiction into effect. The cancellation of derivative titles was necessary to fully effectuate the reversion of the lots to the government, as ordered in the final decision. On jurisdiction and due process: The Court found that petitioners were not deprived of property without due process. Petitioners derived their rights from Spouses Gaspar, whose titles were declared void due to fraud and misrepresentation. Since Spouses Gaspar had no valid right to transfer, their transferees, and subsequently the petitioners, also acquired no valid right. The indefeasibility of a title does not attach to titles obtained through fraud or misrepresentation. Thus, the cancellation of these derivative titles did not deprive petitioners of a right they legitimately possessed. On the applicability of stare decisis: The Court found that the CA correctly invoked the doctrine of stare decisis. The issues raised by the petitioners in the present case were substantially the same as those raised in the case of Hsi Pin Liu, et al. v. Republic of the Philippines (G.R. No. 231100), which involved the same RTC Order and similar derivative titles. The Court had already dismissed the petition in Liu, making the ruling binding on the present case under the principle of stare decisis et non quieta movere. On substantial compliance with verification and certification: The Court found substantial compliance with the requirements for verification and certification against forum shopping, even though they were signed by counsel. Petitioners, residing abroad, executed Special Powers of Attorney designating their counsel as their attorney-in-fact to sign these documents. This was deemed sufficient to satisfy the purpose of the rules, which is to ensure the truthfulness of allegations and to prevent forum shopping.
Main Doctrine
An order issued during the execution stage of a final and executory judgment, which merely carries out the enforcement of said judgment, is not a judgment, final order, or resolution contemplated under Rule 47 of the Rules of Court, and thus cannot be a subject of an annulment of judgment. The residual authority of the court to issue auxiliary writs and processes to carry its jurisdiction into effect may be invoked for such enforcement.