Rodriguez v. CA

G.R. No. 123026 (September 4, 1996)

SC upheld Rodriguez's win over the property auction, rejecting Sanchez's ownership claims.

Facts:

In a decision rendered on April 30, 1976, the Court of First Instance of Bulacan, Branch IV, ordered Genoveva Laxamana, the predecessor in interest of private respondent Apolinario Sanchez, to pay petitioner Jaime R. Rodriguez the sum of P7,500.00, plus interest and attorney's fees amounting to P1,500.00. By October 13, 1977, the decision had become final and executory, but the judgment against Laxamana remained unsatisfied. Consequently, property registered under Transfer Certificate of Title (TCT) No. T-122794 in Laxamana's name was sold at a public auction, with Rodriguez as the highest bidder. A final deed of sale was issued to Rodriguez on March 1, 1982, and TCT No. T-305937 was subsequently issued in his name on November 17, 1986.

On July 8, 1983, the trial court granted a motion for execution filed by Rodriguez on February 14, 1979. Following this, on August 29, 1988, the court issued a writ of possession at Rodriguez's request. On September 23, 1988, Sanchez filed a third-party claim, asserting that Laxamana had sold the land to him on March 30, 1982. The trial court dismissed Sanchez's claim, and a writ of demolition was issued against him on December 14, 1989. Sanchez's petition for certiorari in the Court of Appeals was also dismissed.

On September 8, 1991, Sanchez filed a complaint for annulment of the sale to Rodriguez and obtained a writ of preliminary injunction from the Regional Trial Court (RTC) of Bulacan, which was later set aside by the appellate court. Rodriguez filed a motion for an alias writ of demolition on August 19, 1994, which the trial court granted on October 10, 1994. A second alias writ of demolition was also granted on July 10, 1995.

Sanchez filed a third petition for certiorari in the Court of Appeals, which ruled on October 26, 1995, that the writs of execution, possession, and demolition were void due to the expiration of the five-year period for execution. The appellate court declared the sale of the property at public auction null and void for lack of an order for such sale.

Legal Issues:

  1. Whether the Court of Appeals erred in declaring the writs of execution, possession, and demolition void due to the expiration of the five-year period for execution.
  2. Whether the sale of the property at public auction was valid despite the claims of Sanchez.
  3. Whether Sanchez had a superior claim to the property over Rodriguez.

Arguments:

  • Petitioner (Rodriguez):

    • Rodriguez contended that there was an order dated February 23, 1979, from the RTC for the sale of the property, which was within the five-year period for execution. He argued that the motions and orders issued after five years were merely ancillary to the original order for execution.
    • He asserted that the appellate court's ruling was erroneous as it failed to recognize the existence of the February 23, 1979 order, which authorized the sale.
    • Rodriguez maintained that Sanchez's claim was barred by res judicata due to previous decisions of the Court of Appeals.

  • Respondent (Sanchez):

    • Sanchez argued that the sale to Rodriguez was void because the execution and subsequent orders were issued after the five-year period had lapsed.
    • He claimed that he had a valid purchase of the property from Laxamana on March 30, 1982, and thus had superior rights to the property.

Court's Decision and Legal Reasoning:

The Supreme Court found merit in Rodriguez's petition, reversing the decision of the Court of Appeals. The Court held that the appellate court erred in concluding that the auction sale was void due to the expiration of the five-year period for execution. The Court clarified that the motion for execution filed by Rodriguez was granted by an order dated February 23, 1979, which authorized the sale of the property on April 30, 1979. The subsequent orders issued were merely to implement the earlier order and did not constitute new executions.

The Court emphasized that the absence of the February 23, 1979 order in the records did not negate its existence, and it was incumbent upon Sanchez to prove that the order did not exist. The Court also noted that Sanchez's claim to the property was inferior to Rodriguez's registered title, which was issued after the public auction and subsequent sale.

The Court reiterated the principle that third-party claims over properties levied for execution should be resolved in a separate reivindicatory action, not in the execution proceedings. Sanchez's failure to pursue this remedy further weakened his position.

Significant Legal Principles Established:

  1. The validity of a sale at public auction is contingent upon the existence of a valid order for execution within the prescribed period.
  2. Orders issued after the expiration of the execution period that merely implement prior valid orders do not invalidate the execution process.
  3. Third-party claims over properties levied for execution must be resolved in separate actions, emphasizing the need for due process in adjudicating ownership disputes.