GR 132537; (October, 2005) (Digest)
G.R. No. 132537 October 14, 2005
MARY JOSEPHINE GOMEZ and EUGENIA SOCORRO C. GOMEZ-SALCEDO, Petitioners, vs. ROEL, NOEL and JANNETTE BEVERLY STA. INES and HINAHON STA. INES, Respondents.
FACTS
Petitioners Mary Josephine Gomez and Eugenia Socorro Gomez-Salcedo obtained a final judgment for damages against Marietta Sta. Ines from the Pasig RTC. To satisfy the judgment, the sheriff levied upon and sold at public auction a property in Bayombong, Nueva Vizcaya, registered in Marietta’s name. Petitioners were the highest bidders.
Respondents, comprising Marietta’s husband Hinahon and their children, filed a complaint for annulment of the sheriff’s sale before the RTC of Bayombong, Nueva Vizcaya. They claimed the levied property was their family residence, exempt from execution under the Rules of Court and the Family Code. Petitioners moved to dismiss, arguing the Nueva Vizcaya RTC lacked jurisdiction because the case involved the execution of a final judgment from the Pasig RTC.
ISSUE
Whether the Regional Trial Court of Bayombong, Nueva Vizcaya, has jurisdiction over the complaint for annulment of the sheriff’s sale filed by respondents.
RULING
Yes, the RTC of Nueva Vizcaya has jurisdiction. The Supreme Court affirmed the Court of Appeals’ ruling, which reinstated the complaint. The legal logic is grounded in the nature of the action and the rules on venue. Respondents’ complaint is an independent action for annulment of a sheriff’s sale, not a mere continuation of the execution proceedings from Pasig. As third-party claimants who were not parties to the original case, their remedy is a separate action to assert their superior right over the levied property, which they claim as a family home.
Jurisdiction over such an independent action is determined by the rules on real actions. Under Section 2, Rule 4 of the Rules of Court, actions affecting title to or possession of real property shall be commenced in the proper court where the property lies. The subject property is located in Bayombong, Nueva Vizcaya, placing it within the territorial jurisdiction of the Nueva Vizcaya RTC. The Pasig RTC lost jurisdiction over the main case after its judgment became final and executory, except for purely incidental execution matters. A claim by non-parties asserting ownership or a legal exemption (like the family home) transcends mere execution and constitutes a distinct cause of action properly filed where the property is situated. Therefore, the Nueva Vizcaya court correctly assumed jurisdiction.