G.R. No. 143606 ; June 29, 2005
RUBEN S. SIA, petitioner, vs. HEIRS OF JOSE P. MARIANO, TESTATE ESTATE OF IRENE P. MARIANO, and ERLINDA MARIANO-VILLANUEVA, respondents.

FACTS

Spouses Macario and Irene Mariano owned several parcels of land. Upon Macario’s death, Irene and their adopted children, Jose and Erlinda, executed an extrajudicial settlement. Irene later executed an Affidavit of Merger, consolidating the titles solely in her name. After marrying Rolando Relucio, Irene sold multiple lots, including Lot 15-C, to Raul Santos, Rolando’s cousin. In a separate proceeding, Lot 15-C was levied upon and sold at a public auction to Ruben Sia. Jose and Erlinda subsequently filed a complaint to annul the sales to Raul Santos, alleging forgery and simulation.
The trial court upheld the sales’ validity. On appeal, the Court of Appeals declared the deeds of sale simulated and void, ordering the cancellation of the derived titles. In its dispositive portion, the CA also declared that the heirs of Jose and Erlinda have the right to redeem Lot 15-C from Ruben Sia. Ruben Sia filed this petition, challenging specifically the CA’s declaration regarding the right of redemption over Lot 15-C.

ISSUE

Whether the Court of Appeals erred in declaring that the respondents have the right to redeem Lot 15-C from petitioner Ruben Sia.

RULING

The Supreme Court granted the petition and deleted the CA’s declaration on the right of redemption. The legal logic is anchored on the principle of finality and immutability of judgments, and the specific procedural history of the case concerning Lot 15-C. The Court noted that in a prior and separate case, G.R. Nos. 94617 and 95281 (Villanueva v. Malaya), promulgated on April 12, 2000, it had already nullified the auction sale of Lot 15-C to Ruben Sia and the corresponding writ of execution. That decision became final on October 16, 2000.
Since the Supreme Court had already definitively ruled on the validity of Ruben Sia’s acquisition of Lot 15-C in a final decision, the Court of Appeals’ subsequent declaration in May 2000 regarding a right of redemption was improper. A right of redemption presupposes a valid foreclosure or execution sale. The final ruling in Villanueva nullifying the very sale to Sia removed the legal basis for any redemption. The CA’s declaration was therefore a superfluity and an encroachment on a matter already settled with finality by the Supreme Court. The Court ordered the deletion of the contested portion, subject to the final outcome of the related cases mentioned.