G.R. No. 169214 ; June 19, 2013
SPOUSES MANUEL SY and VICTORIA SY, Petitioners, vs. GENALYN D. YOUNG, Respondent.

FACTS

The case originated from a Complaint for Nullification of Second Supplemental Extrajudicial Settlement, Mortgage, Foreclosure Sale and Tax Declaration filed by respondent Genalyn D. Young with the RTC of San Pablo City. Genalyn, the legitimate daughter of spouses George Young and Lilia Dy, alleged that upon George’s death, he left an unregistered parcel of land. On September 3, 1993, Lilia executed a Second Supplemental to the Deed of Extrajudicial Partition, adjudicating the property solely to herself, while representing the then-minor Genalyn. Lilia later obtained a loan from petitioner-spouses Manuel and Victoria Sy, using the property as security. Upon Lilia’s default, the property was foreclosed and sold to the spouses Sy, who subsequently registered the certificate of sale and obtained a tax declaration in their name.
Genalyn argued the partition was unenforceable as she was a minor and it lacked court approval. She also asserted the spouses Sy knew Lilia was unauthorized to mortgage the property. On July 20, 2000, Genalyn filed a Motion to Admit a Supplemental Complaint, invoking her right to legal redemption as a co-owner. The RTC denied this motion. Genalyn filed a petition for certiorari with the CA (CA-G.R. Sp. No. 65629), which was denied, leading her to elevate it to the Supreme Court (G.R. No. 157955).
Meanwhile, trial at the RTC continued. Genalyn moved to suspend proceedings pending the CA’s decision on the supplemental complaint, but the RTC denied the motion. On August 29, 2001, Genalyn filed a Motion to Cancel Hearing due to indisposition. Consequently, the RTC issued an Order dated August 30, 2001, dismissing the complaint on the ground of non-suit. The RTC denied reconsideration in Orders dated January 4, 2002, and January 16, 2002 (correcting a typographical error).
On January 31, 2002, Genalyn filed an ordinary appeal (CA-G.R. SP No. 74045) questioning these RTC Orders. Subsequently, on May 28, 2002, she filed a separate petition for certiorari under Rule 65 with the CA to annul the same Orders. The CA denied this Rule 65 petition. Genalyn then filed a petition for review under Rule 45 with the Supreme Court ( G.R. No. 157745 ), which was consolidated with G.R. No. 157955.
Regarding CA-G.R. CV No. 74045 (the ordinary appeal), the CA reversed the RTC’s dismissal and remanded the case for further proceedings. The CA denied the spouses Sy’s motion for reconsideration, prompting them to file the present petition ( G.R. No. 169214 ).
In a prior decision dated September 26, 2006, in the consolidated cases “Young v. Spouses Sy,” the Supreme Court: (1) In G.R. No. 157955, granted Genalyn’s petition, ruling that her right to legal redemption stemmed directly from her rights as a co-owner and was dependent on the nullification of the partition, and ordered the RTC to admit the supplemental complaint; (2) In G.R. No. 157745 , denied Genalyn’s petition, holding she had engaged in forum shopping by simultaneously pursuing an ordinary appeal and a Rule 65 petition concerning the same RTC Orders. Entry of judgment in “Young” was made on March 19, 2007.

ISSUE

1. Whether the Court of Appeals erred in setting aside the RTC Orders dated August 30, 2001, January 4, 2002, and January 16, 2002, which dismissed the case for non-suit.
2. Whether the Court of Appeals erred in not holding Genalyn guilty of forum shopping in its Decision dated March 30, 2005, and Resolution dated August 8, 2005.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA Decision and Resolution.
The Court ruled that the present action is barred by the “law of the case” doctrine. The “law of the case” refers to the controlling legal rule established in a former appeal in the same case, which continues to govern as long as the facts remain the same. It applies only to the same case and relates entirely to questions of law, differing from res judicata, which applies to different cases and concerns conclusive determinations of fact and law.
The rationale is to prevent endless litigation and ensure appellate courts can perform their duties efficiently, without parties relitigating issues already gravely ruled upon.
In the prior consolidated case of Young v. Spouses Sy, the Supreme Court had already definitively resolved the very issues raised by the spouses Sy in the present petition:
1. The Court had directed the RTC to admit Genalyn’s supplemental complaint and, by necessary implication, vacated the RTC Orders that dismissed her complaint for failure to prosecute. The dismissal stemmed from the RTC’s erroneous refusal to admit the supplemental complaint.
2. The Court had unequivocally settled that Genalyn committed forum shopping when she filed an ordinary appeal and a petition for certiorari successively regarding the same RTC Orders.
Therefore, the ruling in Young v. Spouses Sy constitutes the law of the case and is controlling. The Supreme Court upheld this prior ruling as the applicable doctrine, leading to the denial of the spouses Sy’s petition.