G.R. No. 108015 and G.R. No. 109234 May 20, 1998.
CRISTINA DE KNECHT and RENE KNECHT, petitioners, vs. HON. COURT OF APPEALS; HON. MANUEL DUMATOL, as Judge, Regional Trial Court, Branch 112, Pasay City; HON. CONCHITA C. MORALES, as Judge, Regional Trial Court, Branch 110, Pasay City; HON. AURORA NAVARETTE-RECINA, as Judge, Regional Trial Court, Branch 119, Pasay City; HON. SOFRONIO G. SAYO, as Judge, Regional Trial Court, Branch 111, Pasay City; REPUBLIC OF THE PHILIPPINES; SPS. MARIANO & ANACORETA NOCOM; SALEM INVESTMENT CORPORATION; SPS. ANASTACIO & FELISA BABIERA; and SPS. ALEJANDRO & FLOR SANGALANG, respondents. (G.R. No. 108015)
CRISTINA DE KNECHT and RENE KNECHT, petitioners, vs. HON. SOFRONIO SAYO, as Judge, Regional Trial Court, Branch 111, Pasay City; REPUBLIC OF THE PHILIPPINES; PHILIPPINE NATIONAL BANK; and MARIANO NOCOM, respondent. (G.R. No. 109234)
FACTS
Petitioners Cristina de Knecht and Rene Knecht owned a parcel of land in Pasay City under TCT No. 9032, on which they constructed eight houses. In 1979, the Republic initiated expropriation proceedings (Civil Case No. 7001-P), but this Court annulled the writ of possession. In 1982, the City Treasurer sold the property at public auction due to unpaid real estate taxes from 1980 to 1982. Respondents Spouses Anastacio and Felisa Babiera and Spouses Alejandro and Flor Sangalang were the highest bidders. Petitioners failed to redeem the property. In 1983, Babiera and Sangalang separately filed petitions for registration (LRC Case No. 2636-P and LRC Case No. 2652-P) which were granted without notice to petitioners, leading to the cancellation of TCT No. 9032 and the issuance of TCT No. 86670 in the names of Babiera and Sangalang. In 1985, Sangalang and Babiera sold the land to respondent Salem Investment Corporation, and TCT No. 94059 was issued to Salem. Meanwhile, Batas Pambansa Blg. 340 was passed in 1983, authorizing the expropriation of the property, which this Court upheld in 1990. In 1985, petitioners filed Civil Case No. 2961-P for reconveyance and annulment of the tax sale and titles. This case was dismissed in 1988 for petitioners’ apparent lack of interest, and the dismissal became final in 1990. In 1990, the Republic filed Civil Case No. 7327 for determination of just compensation under B.P. Blg. 340, naming Salem and others as defendants. The court issued a writ of possession, and seven of petitioners’ houses were demolished. Salem later sold a portion to respondents Spouses Mariano and Anacoreta Nocom. Petitioners refused to vacate their remaining house, leading to an ejectment case and the demolition of their last house in 1991. The trial court in Civil Case No. 7327 issued orders for partial payment of just compensation to Salem and Nocom and fixed the land’s value. In September 1991, petitioners filed a “Motion for Intervention and to Implead Additional Parties” in Civil Case No. 7327, which was denied by the trial court on April 14, 1992. The Court of Appeals dismissed petitioners’ petition challenging this denial. Petitioners also filed Civil Case No. 8423 for recovery of ownership, which was dismissed on the ground of res judicata, a dismissal affirmed by this Court.
ISSUE
The primary issue is whether the Court of Appeals erred in dismissing the petitions and denying petitioners’ intervention in Civil Case No. 7327, effectively ruling that petitioners no longer had any legal interest in the subject property following the final dismissal of their earlier action for reconveyance (Civil Case No. 2961-P).
RULING
The Supreme Court denied the petitions. The Court held that petitioners lost all their rights to the subject property when they failed to redeem it after the tax sale. Their title was extinguished upon the expiration of the redemption period. The subsequent registration proceedings by the buyers, though allegedly conducted without notice, did not invalidate the tax sale itself. The Court further ruled that the dismissal of Civil Case No. 2961-P for reconveyance constituted res judicata, barring petitioners from re-litigating their claim of ownership. The dismissal, which became final and executory, settled the issue of ownership against petitioners. Consequently, petitioners had no remaining legal interest that would entitle them to intervene in the expropriation proceedings (Civil Case No. 7327) for the determination of just compensation. The right to compensation pertains to the registered owner at the time of taking, which was no longer petitioners. The Court found no merit in petitioners’ claims and affirmed the decisions of the Court of Appeals.
