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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
November-2001 Jurisprudence                 

  • G.R. No. 137968 November 6, 2001 - PEOPLE OF THE PHIL. v. ALEJANDRE DELOS SANTOS

  • G.R. Nos. 123138-39 November 8, 2001 - PEOPLE OF THE PHILS. v. HONESTO LLANDELAR

  • A.M. MTJ-01-1375 November 13, 2001 - REPORT ON THE JUDICIAL AUDIT IN THE MTCs of CALASIAO. BINMALEY

  • A.M. No. RTJ-00-1601 November 13, 2001 - ELIEZER A. SIBAYAN-JOAQUIN v. ROBERTO S. JAVELLANA

  • G.R. No. 104629 November 13, 2001 - PEOPLE OF THE PHIL. v. JULIUS KINOK

  • G.R. No. 134498 November 13, 2001 - CELIA M. MERIZ v. PEOPLE OF THE PHIL

  • G.R. Nos. 135454-56 November 13, 2001 - PEOPLE OF THE PHIL v. RODERICK SANTOS

  • A.M. No. CA-01-10-P November 14, 2001 - ALDA C. FLORIA v. CURIE F. SUNGA, ET AL.

  • A.M. No. P-01-1518 November 14, 2001 - ANTONIO A. ARROYO v. SANCHO L. ALCANTARA

  • G.R. No. 122736 November 14, 2001 - PEOPLE OF THE PHIL. v. FROILAN PADILLA

  • G.R. No. 123819 November 14, 2001 - PEOPLE OF THE PHIL. v. STEPHEN MARK WHISENHUNT

  • G.R. No. 133877 November 14, 2001 - RIZAL COMMERCIAL BANKING CORPORATION v. ALFA RTW MANUFACTURING CORPORATION

  • G.R. No. 133910 November 14, 2001 - PEOPLE OF THE PHILIPPINES v. JOSE VIRREY y DEHITO

  • G.R. No. 135511-13 November 14, 2001 - THE PEOPLE OF THE PHILIPPINES v. ENTICO MARIANO y EXCONDE

  • G.R. No. 137613 November 14, 2001 - PEOPLE OF THE PHIL. v. ROSALITO CABOQUIN

  • G.R. No. 138914 November 14, 2001 - PEOPLE OF THE PHIL. v. EFREN MANTES, ET AL.

  • G.R. No. 142870 November 14, 2001 - PEOPLE OF THE PHIL. v. DINDO F. PAJOTAL, ET AL.

  • G.R. Nos. 143513 & 143590 November 14, 2001 - POLYTECHNIC UNIVERSITY OF THE PHILIPPINES v. COURT OF APPEALS and FIRESTONE CERAMICS

  • A.M. No. RTJ-00-1599 November 15, 2001 - TRANQUILINO F. MERIS v. JUDGE FLORENTINO M. ALUMBRES

  • G.R. No. 123213 November 15, 2001 - NEPOMUCENA BRUTAS v. COURT OF APPEALS, ET AL.

  • G.R. No. 126584 November 15, 2001 - VALLEY LAND RESOURCES, INC., ET AL. v. VALLEY GOLF CLUB INC.

  • G.R. No. 127897 November 15, 2001 - DELSAN TRANSPORT LINES v. COURT OF APPEALS, ET AL.

  • G.R. No. 129018 November 15, 2001 - CARMELITA LEAÑO v. COURT OF APPEALS, ET AL.

  • G.R. No. 136017 November 15, 2001 - PEOPLE OF THE PHIL. v. JERRY BANTILING

  • G.R. No. 136143 November 15, 2001 - PEOPLE OF THE PHILIPPINES v. AGAPITO CABOTE a.k.a. "PITO"

  • G.R. No. 137255 November 15, 2001 - PEOPLE OF THE PHIL. v. NOEL MAMALAYAN, ET AL.

  • G.R. No. 137369 November 15, 2001 - PEOPLE OF THE PHILIPPINES v. ALIAS KOBEN VISTA

  • G.R. No. 141811 November 15, 2001 - FIRST METRO INVESTMENT CORPORATION v. ESTE DEL SOL MOUNTAIN RESERVE

  • G.R. No. 145275 November 15, 2001 - COMMISSIONER OF INTERNAL REVENUE v. LA CAMPANA FABRICA DE TABACOS

  • G.R. No. 148326 November 15, 2001 - PABLO C. VILLABER Petitioner v. COMMISSION ON ELECTIONS and REP. DOUGLAS R. CAGAS

  • A.M. No. MTJ-01-1382 November 16, 2001 - MARIO W. CHILAGAN v. EMELINA L. CATTILING

  • A.M. No. P-00-1411 November 16, 2001 - FELICIDAD JACOB v. JUDITH T. TAMBO

  • G.R. No. 120274 November 16, 2001 - SPOUSES FRANCISCO A. PADILLA and GERALDINE S. PADILLA v. COURT OF APPEALS and SPOUSES CLAUDIO AÑONUEVO and CARMELITA AÑONUEVO

  • G.R. No. 127003 November 16, 2001 - THE PEOPLE OF THE PHIL v. FAUSTINO GABON

  • G.R. Nos. 132875-76 November 16, 2001 - PEOPLE OF THE PHIL. v. ROMEO G. JALOSJOS

  • G.R. No. 132916 November 16, 2001 - RUFINA TANCINCO v. GSIS, ET AL.

  • G.R. No. 133437 November 16, 2001 - PEOPLE OF THE PHILIPPINES v. RONALD SAMSON

  • G.R. No. 134486 November 16, 2001 - PEOPLE OF THE PHIL. v. CLEMENTE DAYNA

  • G.R. No. 135038 November 16, 2001 - ROLANDO Y. TAN v. COURT OF APPEALS, ET AL.

  • G.R. No. 142654 November 16, 2001 - PEOPLE OF THE PHIL v. ROLANDO MENDOZA

  • G.R. No. 143802 November 16, 2001 - REYNOLAN T. SALES v. SANDIGANBAYAN, ET AL.

  • G.R. No. 129175 November 19, 2001 - RUBEN N. BARRAMEDA, ET AL. v. ROMEO ATIENZA, ET AL.

  • G.R. No. 130945 November 19, 2001 - PEOPLE OF THE PHIL. v. ALBERTO CONDINO

  • G.R. No. 132724 November 19, 2001 - PEOPLE OF THE PHILIPPINES v. RENIEL SANAHON

  • G.R. Nos. 138358-59 November 19, 2001 - PEOPLE OF THE PHIL. v. CLAUDIO B. DELA PEÑA

  • G.R. No. 138661 November 19, 2001 - PEOPLE OF THE PHIL. v. JERSON E. ACOJEDO

  • G.R. No. 140920 November 19, 2001 - JUAN LORENZO B. BORDALLO, ET AL. v. THE PROFESSIONAL REGULATIONS COMMISSION AND THE BOARD OF MARINE DECK OFFICERS

  • G.R. No. 148560 November 19, 2001 - JOSEPH EJERCITO ESTRADA v. SANDIGANBAYAN (Third Division) and PEOPLE OF THE PHILIPPINES

  • G.R. No. 91486 November 20, 2001 - ALBERTO G. PINLAC v. COURT OF APPEALS, ET AL.

  • G.R. No. 122276 November 20, 2001 - RODRIGO ALMUETE ET AL., v. MARCELO ANDRES, ET AL.

  • G.R. No. 126204 November 20, 2001 - NAPOCOR v. PHILIPP BROTHERS OCEANIC

  • G.R. Nos. 126538-39 November 20, 2001 - PEOPLE OF THE PHILIPPINES v. RODELIO MARCELO

  • G.R. No. 129234 November 20, 2001 - THERMPHIL v. COURT OF APPEALS ET AL.

  • G.R. No. 140032 November 20, 2001 - PEOPLE OF THE PHILIPPINES v. ANGEL C. BALDOZ and MARY GRACE NEBRE

  • G.R. No. 140692 November 20, 2001 - ROGELIO C. DAYAN v. BANK OF THE PHILIPPINE ISLANDS, ET AL.

  • G.R. No. 144401 November 20, 2001 - PEOPLE OF THE PHIL. v. JOEL GALISIM

  • A.M. No. MTJ-99-1207 November 21, 2001 - NBI v. FRANCISCO D. VILLANUEVA

  • A.M. No. P- 01-1520 November 21, 2001 - MARILOU A. CABANATAN v. CRISOSTOMO T. MOLINA

  • A.M. Nos. RTJ-00-1561 & RTJ-01-1659 November 21, 2001 - CARINA AGARAO v. Judge JOSE J. PARENTELA

  • G.R. No. 125356 November 21, 2001 - SUPREME TRANSLINER INC. v. HON. COURT OF APPEALS, ET AL.

  • G.R. No. 132839 November 21, 2001 - ERIC C. ONG v. HON. COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES

  • G.R. No. 133879 November 21, 2001 - EQUATORIAL REALTY DEVELOPMENT v. MAYFAIR THEATER

  • G.R. No. 136748 November 21, 2001 - PEOPLE OF THE PHIL. v. JUANITO ET AL.

  • G.R. No. 137457 November 21, 2001 - PEOPLE OF THE PHIL. v. ROSAURO SIA

  • G.R. No. 141881 November 21, 2001 - THE PEOPLE OF THE PHILIPPINES v. VIRGILIO BERNABE y RAFOL

  • A.M. No RTJ-01-1664 November 22, 2001 - ALFREDO CAÑADA v. VICTORINO MONTECILLO

  • G.R. No. 109648 November 22, 2001 - PH CREDIT CORPORATION v. COURT OF APPEALS and CARLOS M. FARRALES

  • G.R. Nos. 111502-04 November 22, 2001 - REYNALDO H. JAYLO, ET AL. v. SANDIGANBAYAN

  • G.R. No. 113218 November 22, 2001 - ALEJANDRO TECSON v. HON. COURT OF APPEALS ET AL.

  • G.R. No. 113541 November 22, 2001 - HONGKONG AND SHANGHAI BANKING CORP. EMPLOYEES UNION v. NLRC, ET AL.

  • G.R. No. 118462 November 22, 2001 - LEOPOLDO GARRIDO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 123893 November 22, 2001 - LUISITO PADILLA , ET AL. v. THE HONORABLE COURT OF APPEALS, ET AL.

  • G.R. No. 129660 November 22, 2001 - BIENVENIDO P. JABAN and LYDIA B. JABAN v. HON. COURT OF APPEALS, ET AL.

  • G.R. No. 130628 November 22, 2001 - PEOPLE OF THE PHIL. v. PAULINO LEONAR

  • G.R. No. 132743 November 22, 2001 - PEOPLE OF THE PHIL. v. MARCIAL CAÑARES Y ORBES

  • G.R. No. 133861 November 22, 2001 - PEOPLE OF THE PHIL. v. ROBERTO SO

  • G.R. Nos. 135853-54 November 22, 2001 - PEOPLE OF THE PHIL. v. OPENIANO LACISTE

  • G.R. No. 135863 November 22, 2001 - PEOPLE OF THE PHIL. v. VlRGILIO LORICA

  • G.R. Nos. 136317-18 November 22, 2001 - PEOPLE OF THE PHIL. v. EDUARDO YAOTO

  • G.R. No. 136586 November 22, 2001 - JON AND MARISSA DE YSASI v. ARTURO AND ESTELA ARCEO

  • G.R. No. 139563 November 22, 2001 - THE PEOPLE OF THE PHIL.. v. AMADOR BISMONTE y BERINGUELA

  • G.R. Nos. 139959-60 November 22, 2001 - PEOPLE OF THE PHIL. v. DEOGRACIAS BURGOS

  • G.R. No. 141602 November 22, 2001 - PACSPORTS PHILS. v. NICCOLO SPORTS, INC.

  • G.R. No. 142316 November 22, 2001 - FRANCISCO A.G. DE LIANO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 143939 November 22, 2001 - HEIRS OF ROSARIO POSADAS REALTY v. ROSENDO.BANTUG

  • G.R. No. 145475 November 22, 2001 - PEOPLE OF THE PHILIPPINES v. EUSEBIO PUNSALAN

  • G.R. No. 145851 November 22, 2001 - ABELARDO B. LICAROS v. THE SANDIGANBAYAN, ET AL.

  • G.R. No. 146683 November 22, 2001 - CIRILA ARCABA v. ERLINDA TABANCURA VDA. DE BATOCAEL, ET AL.

  • A.M. No. RTJ-00-1562 November 23, 2001 - CAVITE CRUSADE FOR GOOD GOVERNMENT v. JUDGE NOVATO CAJIGAL

  • G.R. No. 126334 November 23, 2001 - EMILIO EMNACE v. COURT OF APPEALS, ET AL.

  • G.R. No. 128886 November 23, 2001 - PEOPLE OF THE PHIL. v. JESUS JULIANDA, JR., ET AL.

  • G.R. No. 142044 November 23, 2001 - PEOPLE OF THE PHIL. v. TOBECHUKWU NICHOLAS

  • G.R. No. 144309 November 23, 2001 - SOLID TRIANGLE SALES CORPORATION and ROBERT SITCHON v. THE SHERIFF OF RTC QC, ET AL.

  • A.M. No. RTJ-01-1662 November 26, 2001 - VICTOR TUZON v. LORETO CLORIBEL-PURUGGANAN

  • G.R. No. 138303 November 26, 2001 - PEOPLE OF THE PHIL. v. ELROSWELL MANZANO

  • G.R. Nos. 100940-41 November 27, 2001 - PEOPLE OF THE PHILIPPINES v. AGUSTIN LADAO y LORETO, ET AL.

  • G.R. No. 128285 November 27, 2001 - PEOPLE OF THE PHILS. v. ANTONIO PLANA, ET AL.

  • G.R. Nos. 130409-10 November 27, 2001 - PEOPLE OF THE PHIL. v. JOSUE B. DUMLAO

  • G.R. No. 130907 November 27, 2001 - REPUBLIC OF THE PHIL. v. HON. CESAR A MANGROBANG, ET AL.

  • G.R. No. 130963 November 27, 2001 - PEOPLE OF THE PHIL. v. MARIANO PASCUA

  • G.R. No. 133381 November 27, 2001 - PEOPLE OF THE PHIL. v. ROMULO VILLAVER, ET. AL.

  • G.R. No. 140858 November 27, 2001 - SPOUSES PAPA and LOLITA MANALILI v. SPOUSES ARSENIO and GLICERIA DE LEON

  • G.R. No. 142523 November 27, 2001 - MARIANO L. GUMABON, ET AL. v. AQUILINO T. LARIN

  • G.R. No. 144464 November 27, 2001 - GILDA G. CRUZ and ZENAIDA C. PAITIM v. THE CIVIL SERVICE COMMISSION

  • A.M. No. 00-8-05-SC November 28, 2001 - RE: PROBLEM OF DELAYS IN CASES BEFORE THE SANDIGANBAYAN

  • G.R. No. 128516 November 28, 2001 - DULOS REALTY and DEVELOPMENT CORP. v. COURT OF APPEALS, ET. AL.

  • A.M. No. P-01-1485 November 29, 2001 - OFFICE OF THE COURT ADMINISTRATOR v. MARIE YVETTE GO, ET AL

  • A.M. No. P-01-1522 November 29, 2001 - JUDGE ANTONIO J. FINEZA v. ROMEO P. ARUELO

  • A.M. No. RTJ-01-1665 November 29, 2001 - ROSAURO M. MIRANDA v. JUDGE CESAR A MANGROBANG

  • G.R. No. 119707 November 29, 2001 - VERONICA PADILLO v. COURT OF APPEALS

  • G.R. No. 121703 November 29, 2001 - NATIVIDAD T. TANGALIN v. COURT OF APPEALS, ET AL.

  • G.R. No. 126524 November 29, 2001 - BPI INVESTMENT CORP. v. D.G. CARREON COMMERCIAL CORP., ET AL.

  • G.R. No. 129282 November 29, 2001 - DMPI EMPLOYEES CREDIT COOPERATIVE v. ALEJANDRO M. VELEZ, ET AL.

  • G.R. Nos. 129609 & 135537 November 29, 2001 - RODIL ENTERPRISES v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 130326 & 137868 November 29, 2001 - COMPANIA GENERAL DE TABACOS DE FILIPINAS AND MANILA TOBACCO TRADING v. THE COURT OF APPEALS

  • G.R. Nos. 132066-67 November 29, 2001 - PEOPLE OF THE PHIL. v. BALAS MEDIOS

  • G.R. No. 132133 November 29, 2001 - PEOPLE OF THE PHILIPPINES v. WILLIAM ALPE y CUATRO

  • G.R. No. 136848 November 29, 2001 - PEOPLE OF THE PHIL. v. RENATO T. RAMIREZ

  • G.R. No. 137815 November 29, 2001 - JUANITA T. SERING v. COURT OF APPEALS, ET AL.

  • G.R. No. 138489 November 29, 2001 - ELEANOR DELA CRUZ, ET AL. v. COMMISSION ON AUDIT

  • G.R. No. 139470 November 29, 2001 - PEOPLE OF THE PHIL. v. SPO2 ANTONIO B. BENOZA

  • G.R. No. 140386 November 29, 2001 - PEOPLE OF THE PHIL. v. BENNY ACOSTA

  • G.R. No. 141386 November 29, 2001 - COMMISSION ON AUDIT OF THE PROVINCE OF CEBU v. PROVINCE OF CEBU

  • G.R. Nos. 141702-03 November 29, 2001 - CATHAY PACIFIC AIRWAYS v. NLRC and MARTHA Z. SINGSON

  • G.R. No. 142606 November 29, 2001 - PEOPLE OF THE PHILIPPINES v. NESTOR MUNTA

  • G.R. No. 143127 November 29, 2001 - PEOPLE OF THE PHIL. v. RAUL RUBARES Y CAROLINO

  • G.R. No. 143703 November 29, 2001 - PEOPLE OF THE PHIL v. JOSE V. MUSA

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    G.R. No. 120274   November 16, 2001 - SPOUSES FRANCISCO A. PADILLA and GERALDINE S. PADILLA v. COURT OF APPEALS and SPOUSES CLAUDIO AÑONUEVO and CARMELITA AÑONUEVO

     
    PHILIPPINE SUPREME COURT DECISIONS

    SECOND DIVISION

    [G.R. No. 120274. November 16, 2001.]

    SPOUSES FRANCISCO A. PADILLA and GERALDINE S. PADILLA, Petitioners, v. COURT OF APPEALS and SPOUSES CLAUDIO AÑONUEVO and CARMELITA AÑONUEVO, Respondents.

    R E S O L U T I O N


    QUISUMBING, J.:


    For review is the decision of the Court of Appeals in CA-G.R. CV No. 20442, affirming that of the Regional Trial Court of Quezon City, Branch 86, in Civil Case No. Q-49267, which held that petitioners could not compel private respondents to pay the balance of the purchase price of a parcel of land inasmuch as there was a cloud in the title of petitioners to the land in question.

    The facts of the case, as summarized by the Court of Appeals, are as follows:chanrob1es virtual 1aw library

    Petitioners, spouses Francisco and Geraldine Padilla, are the registered owners of a parcel of land covered by TCT No. 311854 issued on February 24, 1984, by the Register of Deeds of Quezon City. They sold this lot to private respondents, the spouses Claudio and Carmelita Añonuevo, for P875,680, as shown by a deed of absolute sale executed on March 4, 1985. To secure payment of the purchase price, the Añonuevos executed a chattel mortgage over a pleating machine, promising to pay the Padillas said amount in five equal installments.

    On the same day the sale was made, March 4, 1985, Francisco Padilla executed a special power of attorney authorizing the Añonuevos to mortgage the land, to enable them to obtain a loan from the Equitable Venture Capital Corporation.

    On March 8, 1985, the Añonuevos paid the Padillas P175,136 for the installment due on March 31, 1985.

    On March 13, 1985, homeowners of Carmel Subdivisions II and II-A filed a complaint before the Quezon City RTC against the Añonuevos and the city engineer of Quezon City, for quieting of title and damages with preliminary injunction. The homeowners alleged that the lot sold to the Añonuevos is the same lot registered in the name of Carmel Subdivision. This lot, per Resolution No. 3960 of the City Council of Quezon City, was declared an open space for public use. The property was registered in the name of the subdivision under TCT No. 53162 issued by the Registry of Deeds of Quezon City on October 20, 1960, with the same technical description as the lot sold by the Padillas to the Añonuevos.

    The Añonuevos paid the Padillas P75,136 for the second installment due on July 31, 1985. But thereafter they made no other payment, in view of the complaint filed by the Carmel homeowners.

    Consequently, the Padillas sued the Añonuevos to compel payment of the full purchase price. After trial, the RTC ruled that the Padillas did not have any legal or moral right to compel payment since, at the time of the sale, there was a cloud in their title to the property. The Padillas appealed to the Court of Appeals, which affirmed the decision of the RTC but deleted the award of exemplary damages and attorney’s fees.chanrob1es virtua1 1aw 1ibrary

    The CA ruled that the Padillas could not compel payment of the purchase price since they had not complied with their obligation to deliver the subject property to the Añonuevos. According to the CA, there was no tradition in this case, under Article 1498 of the Civil Code, contrary to petitioners’ (Padillas’) claim. For tradition to take place, the vendor must have control over the thing sold so that, at the moment of sale, he could confer to the vendee not only ownership and right of possession but also actual control of the property. However, in the instant case, at the time the deed of absolute sale was executed, petitioners did not have material control of the lot. Carmel homeowners were using the same property as playground and claiming it as open space titled in the name of the subdivision.

    The CA denied petitioners’ motion for reconsideration. Hence, this petition, in which they alleged that, THE COURT OF APPEALS ERRED:chanrob1es virtual 1aw library

    1. IN DISREGARDING AND IGNORING OFFICIAL DOCUMENTS OF THE QUEZON CITY GOVERNMENT CONFIRMING THAT THE SUBJECT LOT IS PRIVATE PROPERTY AND NOT AN OPEN SPACE;

    2. IN HOLDING THAT THE EXECUTION OF THE DEED OF ABSOLUTE SALE OF A PARCEL OF LAND DOES NOT AMOUNT TO TRADITION UNDER ARTICLE 1498 OF THE CIVIL CODE, AND THAT PETITIONERS HAVE FAILED TO FULFILL THEIR OBLIGATION TO DELIVER ACTUAL CONTROL OF THE LOT TO PRIVATE RESPONDENTS;

    3. IN RELYING ON THE CASE OF DANGUILAN V. INTERMEDIATE APPELLATE COURT, 168 SCRA 22, WHEREIN IT WAS HELD THAT THE THING SOLD MUST BE PLACED IN THE ACTUAL CONTROL OF THE VENDEE;

    4. IN RELYING ON THE RULING IN CA-G.R. CV NO. 35119 NOTWITHSTANDING THAT THIS WAS STILL PENDING APPEAL BEFORE THE SUPREME COURT AT THAT TIME;

    5. IN NOT RULING THAT PRIVATE RESPONDENTS HAVE NO RIGHT TO SUSPEND PAYMENT OF THE BALANCE OF THE PURCHASE PRICE;

    6. IN ALLOWING PRIVATE RESPONDENTS TO RETAIN THE LOT IN QUESTION WITHOUT HAVING PAID THEREFOR, ALLOWING THEM TO ENRICH THEMSELVES AT THE EXPENSE OF PETITIONERS; AND

    7. IN NOT ORDERING MUTUAL RESTITUTION BY THE PARTIES, WHICH IS THE RULE IN CASE OF ANNULMENT OR RESCISSION OF A DEED OF ABSOLUTE SALE.1

    When petitioners filed this petition on June 6, 1995, we had already ruled on the issue of the validity or nullity of the title of the spouses Padilla over the subject lot, in G.R. No. 113639, entitled Claudio Añonuevo, Et. Al. v. Court of Appeals, Et. Al. and promulgated on May 2, 1995. We denied reconsideration of said decision in a resolution dated June 7, 1995.

    That case stemmed from a complaint for quieting of title filed by Carmel homeowners against the Añonuevos, with the same factual antecedents as the present case. The trial court found for the Añonuevos but this decision was reversed by the Court of Appeals in CA-G.R. CV No. 35119. On petition for certiorari before this Court, we affirmed the decision of the Court of Appeals, which ruled in this wise:chanrob1es virtual 1aw library

    ACCORDINGLY, in view of all the foregoing, the decision appealed from is hereby REVERSED, and a new one is rendered DECLARING Lot II, Block 6 of LRC Plan PSD-4666, now covered under TCT No. 35735, Registry of Deeds of Quezon City, as an OPEN SPACE for public use and enjoyment; DECLARING as null and void TCT No. 35735 in the name of Francisco Padilla, married to Geraldine Padilla, and all other certificates of title derived therefrom; and, ORDERING Spouses Claudio and Carmelita Añonuevo, and all persons in privy to them, their heirs and assigns, to cease and desist from disturbing the possession and control exercised by the HOMEOWNERS of Carmel II-A Subdivision, over said Lot II, Block 6.

    x       x       x2

    With the above ruling, we are constrained to deny the instant petition for being utterly without merit. On the main issue of payment for the lot, petitioners could not compel private respondents to pay the purchase price for the property whether by installment or in full. For, clearly petitioners had nothing to sell to private respondents, since their title to the property has been declared null and void.chanrob1es virtua1 1aw 1ibrary

    Moreover, on the issue of restitution raised by both petitioners and private respondents, we note that both decisions in CA-G.R. CV No. 20442 and in CA-G.R. CV No. 35119 did not provide for restitution. This issue must now be laid to rest.

    Petitioners admit that private respondents paid them P175,136 for the first installment on the lot, 3 and P75,136 for the second installment, 4 or a total of P250,272. Since petitioners’ title to the property sold was subsequently declared null and void, there could not be any valid sale between the parties as petitioners had nothing to convey to private respondents. Hence, petitioners were not entitled to the installment payments made by private respondents. Thus, petitioners should be ordered to return to private respondents the amounts paid with legal interest yearly of 6% thereon from the time of receipt by petitioners of the installments until fully restituted to private respondents, on the principle that no one may be allowed to unjustly enrich himself at the expense of another. 5

    Petitioners’ view that private respondents should not be allowed to retain the subject lot without having fully paid therefor, as this constitutes unjust enrichment, has boomeranged. They wanted the lot returned to them along with their copy of the TCT, and the rescission of the deed of absolute sale. But petitioners proceeded from the erroneous assumption that the lot was theirs. As earlier stated, this Court has already ruled that petitioners’ title to the lot is null and void. It is now declared as OPEN SPACE for public use and enjoyment under the control of the Homeowners of Carmel II-A subdivision. Clearly, therefore, petitioners could not seek the return to them of a lot not rightfully theirs.chanrob1es virtua1 1aw 1ibrary

    Petitioners also insist that private respondents settle the latter’s mortgage debt with Equitable Venture Capital Corporation, obtained by using the subject lot as security. However, respondent court found that the mortgage was actually entered into in the name of petitioners,6 not private respondents. Thus, we agree that said respondents do not have any loan obligation to Equitable Venture Capital Corporation.

    WHEREFORE, the instant petition is DENIED for being utterly without merit. Petitioners are ordered to return the installment payments in the total of #250,272 with legal interest of 6% yearly from the time of receipt by petitioners of the installment payments until fully restituted to private respondents. Costs against petitioners.

    SO ORDERED.

    Bellosillo, Mendoza, Buena and de Leon, Jr,., JJ., concur.

    Endnotes:



    1. Rollo, pp. 16-17

    2. Añonuevo v. Court of Appeals, 244 SCRA 28, 30 (1995).

    3. Rollo, p. 14.

    4. Id. at 15.

    5. CIVIL CODE, Article 22.

    6. Rollo p. 52.

    G.R. No. 120274   November 16, 2001 - SPOUSES FRANCISCO A. PADILLA and GERALDINE S. PADILLA v. COURT OF APPEALS and SPOUSES CLAUDIO AÑONUEVO and CARMELITA AÑONUEVO


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