Enriquez v. Heirs of Enriquez
REITERATIONFacts
The Antecedents: Petitioners filed a Complaint for Declaration of Nullity and Cancellation of Title and Declaration of Ownership over Lot Nos. 3564, 3566, and 3567 against respondents. Petitioners claimed that their deceased father, Faustino, bought the lots in 1948, and Florencio, his eldest son, was merely named as vendee in the deed of sale. Florencio later executed a Deed of Sale in favor of petitioners in 1952, with an affidavit in 1956 to correct an omission. Petitioners alleged continuous possession and cultivation of the lots. In 2002, respondents demanded petitioners vacate the lots, claiming a free patent and Original Certificate of Title (OCT) No. P-3,588 for Lot No. 3564 were issued in Florencio's name. Petitioners argued the DENR had no jurisdiction as the lots were privately owned. Procedural History: The Regional Trial Court (RTC) issued a Temporary Restraining Order (TRO) enjoining respondents from proceeding with an ejectment case and entering the lots. The RTC later rendered a Decision on July 27, 2009, declaring petitioners as owners and the free patent and OCT null and void, making the WPI permanent and the ejectment case academic. The RTC ruled that petitioners proved ownership through Florencio's deeds and their continuous possession, and that the DENR lacked jurisdiction. The Court of Appeals (CA) reversed the RTC Decision, finding the sale void under the 1935 Constitution as Faustino was a Chinese citizen, and that Florencio's purported deed was unsigned and its due execution unproven. The CA found respondents' OCT and tax declarations sufficient proof of ownership. Petitioners filed an Omnibus Motion for Reconsideration and to Remand, arguing the RTC Decision was premature, rendered without a full trial on the merits, but the CA denied it, citing estoppel. The Petition: Petitioners filed a Petition for Review on Certiorari before the Supreme Court, arguing the CA erred in denying their Omnibus Motion and that the RTC gravely abused its discretion in deciding the case on the merits without a pre-trial and trial.
Issue(s)
Whether the Court of Appeals committed reversible error in denying petitioners' Omnibus Motion on the ground of estoppel. Whether the Regional Trial Court committed grave abuse of discretion in deciding the case on the merits despite the absence of pre-trial and trial on the merits.
Ruling
The Supreme Court granted the Petition for Review on Certiorari, reversed and set aside the assailed Decision and Resolution of the Court of Appeals, and remanded the case to the Regional Trial Court for trial on the merits.
Ratio Decidendi
On the issue of whether the Court of Appeals committed reversible error in denying petitioners' Omnibus Motion on the ground of estoppel: The Supreme Court held that the RTC committed grave abuse of discretion in deciding the case on the merits without a pre-trial and trial. The hearings and evidence presented were solely for the purpose of determining the propriety of issuing a Writ of Preliminary Injunction (WPI). The evidence submitted during the hearing for preliminary injunction is not conclusive and serves only as a "sampling" to give the trial court an idea of the justification for its issuance pending the decision on the merits. Findings of fact and opinions of a court when issuing a WPI are interlocutory and cannot preempt the resolution of the case on the merits. Since the RTC Decision was rendered with grave abuse of discretion, it is void and legally non-existent. Therefore, petitioners were not barred by estoppel from assailing its validity and seeking a remand for trial on the merits. The CA gravely erred in denying the motion for reconsideration on the ground of estoppel, as the elements of estoppel were not fully present, and remanding the case would serve the interest of justice. On the issue of whether the Regional Trial Court committed grave abuse of discretion in deciding the case on the merits despite the absence of pre-trial and trial on the merits: The Supreme Court found that the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction. The RTC explicitly stated in its Decision that "Issues having been joined, pre-trial and trial on the merits proceeded," which contradicted the records showing no pre-trial was conducted and the hearings were for the WPI. A judgment rendered with grave abuse of discretion is void and does not exist in legal contemplation. The CA, in reversing the RTC's ruling, failed to thoroughly consider relevant facts and evidence, such as the Decree No. 702880 in favor of Ong Yok, the recency of respondents' tax declarations, and petitioners' evidence of tax payments dating back to 1980. The Court found that the CA's ruling was based on a misapprehension of facts and conflicting findings with the RTC, thus warranting review under exceptions to the Rule 45 limitations.
Main Doctrine
A judgment rendered with grave abuse of discretion is void and does not exist in legal contemplation, thus, parties are not barred from assailing its validity and seeking a remand for trial on the merits.