Del Mundo v. CA

G.R. No. 108522 (January 29, 1996)

Court upheld writ of execution; deed of sale was simulated, confirming jurisdiction over ejectment case.

Facts:

The case involves a dispute between Gerardo A. Del Mundo (petitioner) and the spouses Carlos and Alejandra Nava (respondents). The spouses owned a house and lot in Project 6, Quezon City, which was mortgaged to the Philippine Veterans Bank. In 1981, before migrating to the United States, the spouses entered into a lease agreement with Del Mundo, allowing him to lease the property for one year with an option to purchase it for P470,000. Del Mundo moved into the property but failed to exercise his option to buy due to financial constraints.

While the spouses were abroad, Del Mundo sent them a Deed of Sale with Assignment of Mortgage, requesting their signatures to facilitate a bank loan for the purchase price. The spouses, trusting Del Mundo, signed the documents without receiving any consideration. However, Del Mundo failed to fulfill his obligations, leading Alejandra Nava to lose faith in him.

On March 16, 1983, the spouses executed a Revocation of the Deed of Sale, which was notarized and certified. Subsequently, they filed an unlawful detainer case against Del Mundo in 1983, which resulted in a decision ordering him to vacate the premises and pay rent and attorney's fees. Del Mundo appealed this decision, and the Regional Trial Court (RTC) later issued a writ of execution pending appeal.

Del Mundo contested the issuance of the writ, claiming that the Metropolitan Trial Court lacked jurisdiction over the ejectment case. He also filed a Petition for Declaratory Relief to Quiet Title, which was dismissed by the RTC, affirming that the Deed of Sale was null and void and that the revocation was valid.

Del Mundo's appeal to the Court of Appeals was dismissed, leading him to file a petition for certiorari before the Supreme Court, seeking to reverse the Court of Appeals' decision and declare the writ of execution null and void.

Legal Issues:

  1. Whether the Deed of Sale with Assignment of Mortgage was valid and supported by consideration.
  2. Whether the issuance of the writ of execution in the unlawful detainer case was proper.
  3. Whether the Metropolitan Trial Court had jurisdiction over the ejectment case.

Arguments:

Petitioner (Del Mundo):

  • Argued that the Deed of Sale was valid and that he had paid the consideration, thus making him the owner of the property.
  • Contended that the RTC and Court of Appeals erred in ruling that the Deed was simulated and made without consideration.
  • Claimed that the Metropolitan Trial Court lacked jurisdiction to decide the ejectment case without addressing ownership issues.
  • Asserted that the writ of execution was issued without proper jurisdiction and that he was deprived of his right to be heard.

Respondents (Nava Spouses):

  • Maintained that the Deed of Sale was invalid due to lack of consideration and that Del Mundo had not fulfilled his obligations.
  • Argued that the Metropolitan Trial Court had jurisdiction to resolve possession issues in the unlawful detainer case, independent of ownership.
  • Supported the issuance of the writ of execution, asserting that Del Mundo's actions were merely delaying tactics.

Court's Decision and Legal Reasoning:

The Supreme Court denied Del Mundo's petition for review, affirming the Court of Appeals' decision. The Court held that the findings of fact by the lower courts were binding and conclusive. It ruled that the Deed of Sale was indeed simulated and made without consideration, as Del Mundo failed to provide sufficient evidence of payment.

The Court clarified that the ejectment case was focused solely on possession, and the Metropolitan Trial Court had the authority to resolve possession issues without determining ownership. The Court also noted that the writ of execution was valid, as it was issued following the proper legal procedures.

The Court reprimanded Del Mundo for employing legal knowledge to delay proceedings and warned that similar future conduct would be dealt with more severely.

Significant Legal Principles Established:

  • The validity of a contract, such as a Deed of Sale, requires consideration; a contract without consideration is void.
  • Ejectment proceedings focus on possession rather than ownership, allowing the court to resolve possession issues independently of ownership disputes.
  • The findings of fact by lower courts are generally binding on higher courts, barring compelling reasons to deviate from them.