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EMERITA MUÑOZ v. ATTY. VICTORIANO R. YABUT

FACTS:

The case revolves around a dispute over ownership and possession of a property located at No. 48 Scout Madriñan St., Diliman, Quezon City. Originally owned by Yee L. Ching, the property was later transferred via a Deed of Absolute Sale on December 22, 1972, to the petitioners, Muñoz. However, another deed dated December 28, 1972, indicated that Muñoz sold the property to Emilia M. Ching, who then sold it to the spouses Go Song and Tan Sio Kien on July 16, 1979. Subsequently, Muñoz registered her adverse claim to the property on October 15, 1979, and filed a complaint seeking annulment of the subsequent deeds of sale, resulting in the issuance of successive Transfer Certificates of Title (TCTs) from TCT No. 186306 in her name to TCT No. 258977 in the spouses Go's name.

Muñoz's adverse claim resulted in prolonged litigation, beginning with Civil Case No. Q-28580 and moving through various courts. The Quezon City Regional Trial Court (RTC) Branch 95, in its decision on July 19, 1991, declared that Muñoz's signature on the December 28, 1972, deed was forged and that she never sold the property to Emilia M. Ching. The RTC's judgment that titles derived from the forged deed were void ab initio was affirmed by the Court of Appeals (CA) and became final and executory in 1993.

However, during the pendency of these legal disputes, the property passed to the Bank of the Philippine Islands (BPI) Family Savings Bank through foreclosure, and then to the spouses Samuel Go Chan and Aida C. Chan via a Deed of Absolute Sale on December 3, 1990. BPI obtained the title through foreclosure on a loan default by the spouses Go, and the property was eventually registered under TCT No. 53297 in the names of the spouses Chan.

Muñoz contested the validity of these transactions and sought enforcement of the RTC judgment in Civil Case No. Q-28580 to cancel subsequent titles and revert ownership to her. She also filed Civil Case No. 8286 against Samuel Go Chan and Atty. Yabut for forcible entry, alleging that she had actual possession following the execution of the RTC judgment but was forcibly dispossessed on February 2, 1994. Muñoz's complaint for forcible entry highlighted incidents of force and intimidation used by Samuel Go Chan and Atty. Yabut to dispossess her.

This consolidated petition concerns Muñoz's plea for the reversal of decisions from the Court of Appeals affirming trial court orders that did not fully implement her claim to the property against BPI Family and the spouses Chan. The key point of conflict here pertains to whether these entities, subsequent purchasers, could be bound by the earlier RTC judgment, despite not being parties during its issuance.

ISSUES:

  1. Issue in G.R. No. 142676:

    • Did the Metropolitan Trial Court (MeTC) err in ordering the dismissal of Civil Case No. 8286, the forcible entry case filed by Emerita Muñoz against Samuel Go Chan and Atty. Yabut?

  2. Issue in G.R. No. 146718:

    • Was it erroneous for the Regional Trial Court (RTC) Branch 95 to deny Muñoz’s Motion for Contempt against and Motion for Alias Writ of Execution against the spouses Chan who were not impleaded in the original Civil Case No. Q-28580?

RULING:

  1. Ruling in G.R. No. 142676

    • The petition is granted. The Court of Appeals' Decision and Resolution, which affirmed the RTC Branch 88 orders, were reversed and set aside. The MeTC is directed to reinstate Muñoz's complaint for forcible entry in Civil Case No. 8286 and to resume proceedings to ascertain if Muñoz was forcibly deprived of possession from February 2, 1994, until the finality of this judgment, and if so, whether she is entitled to damages for that period.

  2. Ruling in G.R. No. 146718

    • The petition is denied for lack of merit. The Court of Appeals' Decision and Resolution, which affirmed the RTC Branch 95 orders that denied Muñoz's motions for contempt and alias writ of execution against the spouses Chan, were affirmed.

PRINCIPLES:

  • Forcible Entry Focuses on recovering prior physical possession unduly deprived by means of force, intimidation, strategy, or stealth. Legal title or ownership is not the concern.

  • Judgment in Personam vs. Judgment in Rem A judgment in personam binds parties and their successors-in-interest but not third parties. A writ of execution can only be enforced against litigants who had their day in court or their successors-in-interest.

  • Indefeasibility of Torrens Title A Torrens title cannot be subject to collateral attack and alterations except through direct proceedings. Even if the root title is void, derivative titles acquired in good faith and for value may still stand.

  • Good Faith Purchase Individuals acquiring titles in good faith and for value without notice of any defect retain their property rights.

  • Summary Procedure Intended to expedite cases without regard to technical rules; certain pleadings, including petitions for certiorari and prohibition against interlocutory orders, are prohibited to avoid delay.