G.R. No. L-51983. February 29, 1988.
ADORACION VALERA BRINGAS, as administratrix of the Estate of Francisco Valera, petitioner, vs. HON. HAROLD M. HERNANDO and HON. LEOPOLDO B. GIRONELLA, Presiding Judges of Branches I & II, CFI of Abra; WENCESLA, MARIA, FELIZA, LEONIDES, GENEROSO & NIEVA, all surnamed VALERA and EVA VALERA PE BENITO, as Administratrix of the Estate of Virgilio Valera, respondents.

FACTS

This case involves a protracted dispute over the estate of Francisco Valera. In prior proceedings, petitioner Adoracion Valera Bringas, declared the acknowledged natural child and administratrix of Francisco’s estate, secured a probate court order in 1964 directing her uncles Celso and Virgilio Valera to pay monthly rentals for their use of Francisco’s share in an ancestral residence. A writ of execution was issued, leading to an auction sale in 1967 where properties of Celso Valera were sold to Adoracion. However, in a separate Supreme Court case (G.R. No. L-27526), the Court nullified the orders, writ, and auction sale insofar as they affected the heirs or estate of Virgilio Valera, ruling that a probate court cannot adjudicate the monetary liabilities of a deceased person (Virgilio) to another estate without proper proceedings in the debtor’s own estate settlement.
Subsequently, the heirs of Celso Valera filed Abra CFI Case No. 1044 against Adoracion to recover the properties sold at the 1967 auction. Respondent Judge Hernando rendered a judgment on the pleadings in their favor, applying the benefits of the L-27526 ruling (which voided proceedings against Virgilio’s estate) to also void the proceedings against Celso’s properties. The Supreme Court initially affirmed this judgment. Adoracion now seeks reconsideration, arguing Case No. 1044 was already dismissed based on prior Supreme Court judgments and that the judgment on the pleadings is void.

ISSUE

Whether the Supreme Court correctly affirmed the judgment on the pleadings which ordered the return of Celso Valera’s properties to his heirs by extending the nullity declared in G.R. No. L-27526 (pertaining to Virgilio’s estate) to cover Celso’s case.

RULING

The Supreme Court DENIED the motion for reconsideration and upheld its affirmance of the judgment on the pleadings. The legal logic is anchored on the principle that a void judgment produces no legal effect. The Court in G.R. No. L-27526 had already declared the foundational probate court orders and the consequent writ of execution and auction sale void as to Virgilio’s heirs. Since Celso Valera was a party-respondent in that very case, the nullity of the execution and sale was a settled matter that directly implicated the properties derived from that void process. The judgment on the pleadings in Case No. 1044 was therefore proper because, given the Supreme Court’s prior voiding of the execution sale, there was no genuine factual issue left to contest—the basis for Adoracion’s acquisition of the properties was null, obligating their return. The Court analogized this to Manila Surety & Fidelity Co., Inc. v. Lim, where amounts paid under a void judgment had to be returned.
The Court rejected Adoracion’s procedural objections. It held that a motion for judgment on the pleadings need not be in writing under the rules then in force, and the court could