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 provincial sheriff levied upon and sold at public auction a property in Bayombong, Nueva Vizcaya, registered in Marietta’s name. Petitioners acquired the property as the highest bidder.
Respondents, comprising Marietta’s husband Hinahon and their children, filed a complaint for annulment of the 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 execution 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 core legal principle is that a third-party claim asserting ownership or a superior right over levied property, especially when based on the exemption of a family home, constitutes an independent action for vindication of title. This action is distinct from the main case where execution is sought.
Jurisdiction over such an independent action is determined by the rules on venue for real actions. Under Section 2, Rule 4 of the Rules of Court, actions affecting title to real property shall be commenced in the court where the property is situated. The levied property is located in Bayombong, Nueva Vizcaya, thus vesting jurisdiction in the RTC of that locality. The Pasig RTC’s jurisdiction was limited to the principal case for damages against Marietta. Its authority over execution does not preclude a separate suit by non-parties (the respondents) whose rights were allegedly violated by the sheriff’s levy on a property they claim as a privileged family home. The respondents, not being parties to the original case, could not have intervened therein and properly sought relief in the place where the property is located.