G.R. No. L-46608 March 8, 1978
ELENA VALDEZ, PEDRO TABELINA, and DOMINGO VALDEZ, petitioners, vs. HON. AGUSTIN C. BAGASO, in his capacity as the Presiding Judge of the Court of First Instance of Nueva Ecija, NATIVIDAD VALDEZ, et al., respondents.

FACTS

Private respondents, heirs of Teodora Bucaneg, sued petitioners to nullify two deeds of absolute sale executed by Bucaneg in favor of petitioners over properties in San Jose, Nueva Ecija, and to partition said properties. The trial court rendered judgment on May 8, 1973, declaring the deeds null and void, ordering the cancellation of the petitioners’ titles, and directing partition among the eight heirs. Petitioners appealed to the Court of Appeals. After the appeal was submitted for decision, the appellate court, on May 11, 1976, issued a Resolution dismissing the appeal and remanding the case to the trial court for proceedings under Rule 69 on partition. It held the trial court’s judgment was interlocutory, as it left the appointment of commissioners and approval of a project of partition to be done.
Invoking the ruling in Miranda v. Court of Appeals, petitioners filed a motion with the trial court on April 5, 1977, praying for remand of the records to the Court of Appeals for a decision on the merits. They argued they had incurred considerable expense perfecting their appeal. The trial court, on June 20, 1977, denied the motion, holding the Appellate Court’s Resolution had become final. Reconsideration was denied on July 22, 1977, prompting this petition for certiorari to set aside the orders and compel remand to the Court of Appeals.

ISSUE

Whether the trial court’s judgment declaring the deeds of sale null and void and ordering partition is a final and appealable judgment, or merely an interlocutory order.

RULING

The Supreme Court granted the petition. The trial court erred in holding the Appellate Court’s remand Resolution was a final judgment. That Resolution was merely interlocutory, as it did not finally dispose of or adjudicate the parties’ rights. The core issue on appeal was the validity of the two conveyances. Unless this issue is definitively resolved, partition would be premature. Contrary to the Appellate Court’s holding, the trial court’s decision was a definitive judgment that decided the parties’ rights upon the issue submitted; it was not interlocutory.
The Court reiterated the doctrine from Miranda v. Court of Appeals, adopting the better rule from H. E. Heacock Co. v. American Trading Co. Where the primary purpose is to ascertain who is the true owner of disputed property, the judgment on that question is on the merits, and any order for an accounting or partition is merely incidental. Considering such a judgment final and appealable serves imperative considerations of public policy and the constitutional mandate for a simplified, just, speedy, and inexpensive determination of every action. It prevents the unbridled power of a court to change its judgment and puts an end to controversy. The judgment of May 8, 1973, which nullified the deeds of sale, was a final and appealable judgment. The partition concerned only the respondents-heirs and was contingent upon the affirmance of the judgment nullifying the sales. The appeal must be returned to the Court of Appeals for a determination on the merits of the validity of the deeds of sale.