G.R. No. 182314 ; November 13, 2013
VIRGINIA Y. GOCHAN, et al., Petitioners, vs. CHARLES MANCAO, Respondent.

FACTS

Petitioners, successors-in-interest of co-owner Felix Gochan, filed a case for legal redemption against the spouses Paray, who had purchased twenty lots from the heirs of another co-owner, Amparo Alo. The lots were part of a subdivision plan and were registered under the names of the original co-owners. The parties settled the case via a Compromise Agreement, which was approved by the Regional Trial Court (RTC) as a judgment. The RTC decision was subsequently annotated on the titles.
Respondent Charles Mancao, a subdivision lot owner who purchased his lots from successors of a different vendee of Alo, filed a petition before the Court of Appeals (CA) to declare the compromise judgment null and void. He alleged that the twenty lots subject of the redemption were designated as road lots serving the entire subdivision. He argued that these road lots, being for public use, were outside the commerce of man and thus could not be validly owned or appropriated by private individuals like the petitioners. His standing was based on his interest as a lot owner whose right of perpetual use over the road lots was prejudiced by the compromise.

ISSUE

Whether the Court of Appeals correctly annulled the RTC’s judgment based on compromise on the ground that the subject properties are road lots beyond the commerce of man.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s decision annulling the RTC judgment. The legal logic rests on the fundamental principle that properties for public use, such as road lots in a subdivision, are outside the commerce of man under Article 420 of the Civil Code. This means they cannot be the subject of private ownership or appropriation. The records, including the original subdivision plan, certifications, and historical documents, conclusively established that the twenty lots in question were designated and intended as road lots for the benefit of all subdivision residents.
Since the properties were legally inalienable, the petitioners had no valid right of legal redemption over them in the first instance. A right of legal redemption presupposes an alienable and registrable property. Consequently, the Compromise Agreement, which involved the transfer of these inalienable road lots, and the RTC judgment approving it were void ab initio for having an illegal object or cause. A judgment void from its inception can be assailed at any time. Respondent, as a subdivision lot owner with a vested interest in the use of these road lots, had the legal standing to challenge the judgment, as it directly impaired his property rights. The Court upheld the CA’s finding that the compromise judgment was a patent nullity.