GR 257814; (February, 2023) (Digest)
G.R. No. 257814 & 257944. February 20, 2023.
ROMULO B. ESTRELLA, CESAR B. ANGELES, AND FELIXBERTO D. AQUINO, ACTING IN BEHALF OF AND AS REPRESENTATIVES OF HEIRS OF BARTOLOME P. RIVERA, ELEUTERIA RIVERA, PELAGIA R. ANGELES, MODESTA R. ANGELES, VENANCIO R. ANGELES, FELIPE R. ANGELES, FIDELA ANGELES, JOSEFA R. AQUINO, GREGORIO AQUINO, AND ROSAURO R. AQUINO OF THE MAYSILO ESTATE, PETITIONERS, VS. SM PRIME HOLDINGS, INC., RESPONDENT. TRI-CITY LANDHOLDINGS, INC., INTERVENOR-RESPONDENT. [G.R. No. 257944] TRI-CITY LANDHOLDINGS, INC., PETITIONER, VS. SM PRIME HOLDINGS, INC. AND ROMULO B. ESTRELLA, CESAR B. ANGELES, AND FELIXBERTO D. AQUINO, ACTING IN BEHALF OF AND AS REPRESENTATIVES OF HEIRS OF BARTOLOME P. RIVERA, ELEUTERIA RIVERA, PELAGIA R. ANGELES, MODESTA R. ANGELES, VENANCIO R. ANGELES, FELIPE R. ANGELES, FIDELA ANGELES, JOSEFA R. AQUINO, GREGORIO AQUINO, AND ROSAURO R. AQUINO OF THE MAYSILO ESTATE, RESPONDENTS.
FACTS
The property subject of the controversy is Lot 7-C-2 or Lot 23-A, which formed part of the Maysilo Estate covered by Original Certificate of Title (OCT) No. 994. In 1961, a group claiming to be heirs of Maria de la Concepcion Vidal, a co-owner of the Maysilo Estate, filed a petition for substitution of their names on OCT No. 994, which was granted. Later, they filed a petition for partition and accounting of the estate. In 2006, Romulo B. Estrella, Cesar B. Angeles, and Felixberto D. Aquino (Estrella et al.), as court-appointed representatives of the alleged Vidal heirs, initiated a civil case for the nullification and cancellation of Transfer Certificate of Title (TCT) No. 326321 against Gotesco Investment, Inc. (Gotesco), claiming the heirs were the real owners of the subject property. They alleged the City of Caloocan sold the property to Gotesco, which secured a new title, despite the heirs never having sold it. SM Prime Holdings, Inc. (SM Prime) later substituted Gotesco as defendant after purchasing the property. Tri-City Landholdings, Inc. (Tri-City) intervened, claiming a Deed of Assignment was executed in 2009 by Estrella et al., assigning the subject property to Tri-City in exchange for shares. The Regional Trial Court (RTC) admitted Tri-City’s intervention but later granted SM Prime’s Demurrer to Evidence and dismissed the complaint and complaint-in-intervention. Estrella et al. and Tri-City appealed to the Court of Appeals (CA). The CA dismissed the appeal for failure of Estrella et al. to file their appellants’ brief on time, considering the appeal abandoned. The CA also dismissed Tri-City’s appeal, noting intervention is ancillary to the main action. The CA further cited Supreme Court rulings in Manotok v. CLT Realty Development Corp. and related cases, which declared that OCT No. 994 dated April 19, 1917 is inexistent, and only OCT No. 994 dated May 3, 1917 is valid, and that titles sourced from the April 19, 1917 date are void.
ISSUE
The primary issue is whether the Court of Appeals correctly dismissed the appeal for failure to file the appellants’ brief on time and whether the intervention could proceed independently. Underlying this is the validity of the claims based on OCT No. 994 dated April 19, 1917.
RULING
The Supreme Court denied the petitions and affirmed the resolutions of the Court of Appeals. The Court held that the CA correctly dismissed the appeal for Estrella et al.’s failure to file the appellants’ brief within the reglementary period, constituting abandonment of the appeal. The negligence of counsel is generally binding on the client, and Estrella et al. failed to justify their failure to monitor their case. The Court also upheld the dismissal of Tri-City’s intervention, as an intervention is merely ancillary and supplemental to the main action and cannot proceed independently once the main action is dismissed. Furthermore, the Court reiterated its final and binding rulings in the Manotok and Araneta cases, which declared that OCT No. 994 dated April 19, 1917 is inexistent and void, and only OCT No. 994 dated May 3, 1917 is valid. Consequently, any title tracing its source to the April 19, 1917 OCT, including the claims of Estrella et al. and Tri-City, is void. The Court emphasized that these prior rulings have conclusively resolved the status of the Maysilo Estate titles and bind all related cases.