Javier v. Court of Appeals
REITERATIONFacts
The Antecedents: Luz Javier executed a Deed of Absolute Sale on March 8, 1972, in favor of the legal heirs of Sabiniano B. Javier, represented by Ursula Ocdamia Javier. The deed excluded an adjoining lot and stipulated that the vendor had a pending application for a permit over that area. Ursula did not register this document. Luz Javier later filed a complaint for rescission of the contract of sale with damages against Ursula. Procedural History: The trial court rendered a decision on February 20, 1984, rescinding the Deed of Absolute Sale and ordering the return of the property and payment of damages and attorney's fees. This decision was affirmed by the Court of Appeals on October 27, 1986, and a petition for review to the Supreme Court was denied with treble costs on January 12, 1987. Entry of judgment was made, and the records were remanded. An alias writ of execution was issued on February 10, 1988. Ursula and the heirs moved to reconsider, presenting a new deed of sale dated March 4, 1975, purportedly from Luz Javier to Ursula, which was registered, resulting in TCT No. T-40968 in Ursula's name. Ursula also filed a separate complaint for quieting of title and damages. The trial court denied the motion for reconsideration of the writ of execution and Ursula's petition for preliminary injunction, and later dismissed the quieting of title complaint based on res judicata. These denials and dismissals were affirmed by the Court of Appeals. The Petition: Petitioners seek to set aside the Court of Appeals' decisions affirming the denial of their motion to suspend the alias writ of execution and the dismissal of their complaint for quieting of title. They argue that the order to deliver the property covered by TCT No. 40968 is void, constitutes a collateral attack on the title, and is moot and academic due to the new title. They also contend that the 1975 deed of sale superseded the 1972 deed, that the rule on finality of judgments admits exceptions, and that their case is not barred by res judicata due to the novel issue of indefeasibility of Ursula's title.
Issue(s)
Whether the subsequent deed of sale dated March 4, 1975, constitutes a supervening event that warrants the suspension or nullification of the execution of the final and executory judgment in the rescission case. Whether the dismissal of the complaint for quieting of title based on res judicata was proper. Whether the enforcement of the writ of execution constitutes a collateral attack on TCT No. T-40968. Whether Ursula Javier was a real party-in-interest in the rescission case. Whether the enforcement of the judgment should be enforced.
Ruling
The petitions are denied, and the decisions of the Court of Appeals are affirmed. Petitioners are directed to comply with the final and executory judgment of the Regional Trial Court in the rescission case.
Ratio Decidendi
On the issue of supervening event and the subsequent deed of sale: The Court held that the alleged deed of sale dated March 4, 1975, cannot be considered a supervening event that would alter the finality and executory nature of the decisions. A supervening event must transpire after the judgment has become executory and affect the substance of the judgment, rendering its execution inequitable. The records show that the complaint for rescission was filed in 1976, and Ursula and the legal heirs remained silent about the alleged 1975 deed of sale throughout the proceedings until after the judgment became final and executory in 1987. Attempts to frustrate the enforcement of an executory judgment based on facts occurring before its finality cannot succeed. Facts bearing on the substance of the obligation should be alleged and proved during the trial or before the judgment becomes final. On the issue of res judicata: The Court found that all the essential requisites of res judicata are present: (a) the former judgment (rescission case) is final; (b) it was rendered by a court with jurisdiction; (c) it was a judgment on the merits; and (d) there is identity of parties, subject matter, and cause of action between the rescission case and the quieting of title case. The private respondents are the heirs of Luz Javier, who instituted the rescission case, and they inherited the disputed property. The subject matter and cause of action in both cases involve conflicting claims of ownership over the same property. Therefore, Ursula's belated efforts to question the judgment are barred by res judicata. The principle of res judicata bars not only the relitigation of issues squarely raised but also any other issue that could have been raised in the first suit. On the issue of collateral attack on the Torrens title: The Court ruled that even granting the existence of the second sale, Ursula's assertion is without merit. The Land Registration Act protects purchasers in good faith and for value, but it cannot be used as a shield for fraud. Ursula knew that Luz Javier had already ceded the property to her children. Therefore, at the time of the alleged second sale in 1975, Luz Javier was no longer the owner and could not convey what she did not own. Ursula cannot claim a superior right under the second sale. Registration does not vest title if done in bad faith. A person who wrongfully registers property in their name holds it in trust for the real owner, who has the right to file an action for reconveyance, which is imprescriptible. The judgment in the rescission case already directed the reconveyance. On Ursula's claim of not being a real party-in-interest: The Court dismissed this contention as mere hair-splitting. Ursula's answer in the rescission case clearly indicated she considered herself a party in her own individual right, not just as a representative of her children. She actively participated in the proceedings and cannot now claim she was not a real party-in-interest. The fact that she did not object to being named a defendant and that Luz Javier later amended the complaint to include her children as co-defendants does not negate Ursula's own standing as a party. On the enforcement of the judgment: The Court emphasized that the enforcement of the final judgment in the rescission case had been long delayed. In the interest of justice and without ordering the cancellation of Ursula's title, she and the legal heirs must comply with the final and executory judgment, as it would be unjust for her to retain property over which she has no valid right.
Main Doctrine
A subsequent deed of sale, if discovered after a judgment has become final and executory, cannot be considered a supervening event that would justify the suspension or nullification of the execution of such judgment, as it pertains to facts or events occurring before the judgment became final and should have been raised during the trial.