Lawyerly

GR No. 149548

2009-12-04

CARPIO MORALES, J.

The only recognized exceptions to the foregoing doctrine are the corrections of clerical errors or the making of the so-called nunc pro tunc entries, which cause no prejudice to any party, and, where the judgment is void.[75] Void judgments may be classified into two groups: those rendered by a court without jurisdiction to do so and those obtained by fraud or collusion.[76] None of these exceptions can be applied to the final and executory judgment of the Court of Appeals in CA-G.R. SP No. 36299.

GR Nos. 162335 & 162605

2008-12-18

SEVERINO M. MANOTOK IV v. HEIRS OF HOMER L. BARQUE

TINGA, J.

These petitions were referred to the Court en banc by the Special First Division which had initially ruled on them, most comprehensively in a Decision dated 12 December 2005.[4] They were accepted by the Court en banc in a Resolution dated 26 July 2006. Subsequently, the parties presented their various contentions before the Court in an oral argument held on 24 July 2007, followed by the submission of their respective memoranda. While the cases were under consideration of the Court en banc, the participation of the Office of the Solicitor General was required,[5] and a set of new parties was allowed leave to intervene.[6]

GR NO. 151854

2008-09-03

PHILUX v. NLRC

LEONARDO-DE CASTRO, J.

The decision in Legarda v. Court of Appeals[24] also invoked by petitioners, that the alleged reckless, inexcusable and gross negligence of counsel resulted in the deprivation of the client's property without due process of law, was modified on reconsideration in our en banc Resolution dated October 16, 1997.[25] The Court held:xxx as long as a party was given the opportunity to defend her interests in due course, she cannot be said to have been denied due process of law, for this opportunity to be heard is the very essence of due process. The chronology of events shows that the case took its regular course in the trial and appellate courts but Legarda's counsel failed to act as any ordinary counsel should have acted, his negligence every step of the way amounting to "abandonment, " in the words of the Gancayco decision. Yet, it cannot be denied that the proceedings which led to the filing of this case were not attended by any irregularity. The judgment by default was valid, so was the ensuing sale at public auction. If Cabrera was adjudged highest bidder in said auction sale, it was not through any machination on his part. All of his actuations that led to the final registration of the title in his name were aboveboard, untainted by any irregularity.

GR No. 156078

2008-03-14

MARASIGAN v. MARASIGAN

CHICO-NAZARIO, J.

As the Court of Appeals declared, due process is not a mantra, the mere invocation of which shall warrant a reversal of a decision. Well-settled is the rule that the essence of due process is the opportunity to be heard. In Legarda v. Court of Appeals,[46] the Court held that as long as parties to a case were given the opportunity to defend their interest in due course, they cannot be said to have been denied due process of the law. Neither do the records show any indicia that the preference of petitioners for the physical subdivision of the property was not taken into consideration by the Commissioners.

GR No. 174219

2007-11-23

KLT FRUITS v. WSR FRUITS

CHICO-NAZARIO, J.

As to the existence of a meritorious defense which warrants a further hearing of the case, KLT insist that the checks in question were forged[34] or stolen from the vault of KLT by Leopoldo Gonzales, and that Gonzales admitted that he was the author of the forgery and theft. The forgery and theft of the checks in question will prevent WSR from recovering from KLT the value of the said checks. It bears stressing, though, that the RTC did not give due credence to the claim of forgery by KLT that would insulate it from liability for the amount of the checks. All told, the instant case underwent a full-blown trial, in which both parties presented evidence including rebuttal and sur-rebuttal evidence. Where a party was given the opportunity to defend its interest in due course, it cannot be said to have been denied due process of law, for this opportunity to be heard is the very essence of due process.[35] It must be emphasized that KLT was adequately heard, and that all issues were ventilated before the Decision was promulgated. All the necessary pleadings were filed by KLT's counsel to protect its interests when the case was still before the RTC. KLT was not deprived of its day in court.[36] No denial of due process was shown. Verily, KLT was afforded adequate and full opportunity to ventilate its case in the proceedings below.

GR NO. 158585

2005-12-13

AMON TRADING CORPORATION v. CA

CHICO-NAZARIO, J.

Considering the vagaries of the case, private respondent brought the wrong upon itself. As adeptly surmised by the trial court, between petitioners and private respondent, it is the latter who had made possible the wrong that was perpetuated by Eleanor Sanchez against it so it must bear its own loss. It is in this sense that we must apply the equitable maxim that "as between two innocent parties, the one who made it possible for the wrong to be done should be the one to bear the resulting loss."[15] First, private respondent was the one who had reposed too much trust on Eleanor Sanchez for the latter to source its cement needs. Second, it failed to employ safety nets to steer clear of the rip-off. For such huge sums of money involved in this case, it is surprising that a corporation such as private respondent would pay its construction materials in advance instead of in credit thus opening a window of opportunity for Eleanor Sanchez or Lines & Spaces to pocket the remaining balance of the amount paid corresponding to the undelivered materials. Private respondent likewise paid in advance the commission of Eleanor Sanchez for the materials that have yet to be delivered so it really had no means of control over her. Finally, there is no paper trail linking private respondent to petitioners thereby leaving the latter clueless that private respondent was their true client. Private respondent should have, at the very least, required petitioners to sign the check vouchers or to issue receipts for the advance payments so that it could have a hold on petitioners. In this case, it was the representative of Lines & Spaces who signed the check vouchers. For its failure to establish any of these deterrent measures, private respondent incurred the risk of not being able to recoup the value of the materials it had paid good money for.

GR NO. 161861

2005-03-11

SPS. WILLIAM AND JULIE LIM v. CHUATOCO

TINGA, J.

Guided by previous decisions of this Court, good faith consists in the possessor's belief that the person from whom he received the thing was the owner of the same and could convey his title. Good faith, while it is always to be presumed in the absence of proof to the contrary, requires a well founded belief that the person from whom title was received was himself the owner of the land, with the right to convey it. There is good faith where there is an honest intention to abstain from taking any unconscientious advantage from another. Otherwise stated, good faith is the opposite of fraud and it refers to the state of mind which is manifested by the acts of the individual concerned.[17] Consistently, this Court has ruled that every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property. A person is charged with notice only of such burdens and claims as are annotated on the title.[18] Thus, where there is nothing in the certificate of title to indicate any cloud or vice in the ownership of the property, or any encumbrance thereon, the purchaser is not required to explore further than what the Torrens Title upon its face indicates in quest for any hidden defects or inchoate right that may subsequently defeat his right thereto.[19]

GR No. 141145

2004-11-12

REPUBLIC v. WILSON P. ORFINADA

SANDOVAL-GUTIERREZ, J.

In Legarda vs. Court of Appeals,[10] we sustained the buyer's right to rely on the correctness of the certificate of title, thus:"If a person purchases a piece of land on the assurance that the seller's title thereto is valid, she should not run the risk of being told later that her acquisition was ineffectual after all. If we were to void a sale of property covered by a clean and unencumbered torrens title, public confidence in the Torrens System would be eroded and land transactions would have to be attended by complicated and inconclusive investigations and uncertain proof of ownership. The consequence would be that land conflicts could proliferate and become more abrasive, if not even violent."

GR No. 156580

2004-06-14

LUZ DU v. STRONGHOLD INSURANCE CO.

PANGANIBAN, J.

If either the third-party claim or the subsequent registration of the prior sale was insufficient to defeat the previously registered attachment lien, as ruled by the Court in Capistrano, it follows that a notice of lis pendens is likewise insufficient for the same purpose. Such notice does not establish a lien or an encumbrance on the property affected.[18] As the name suggests, a notice of lis pendens with respect to a disputed property is intended merely to inform third persons that any of their transactions in connection therewith -- if entered into subsequent to the notation -- would be subject to the result of the suit.

GR No. 141407

2002-09-09

LAPULAPU DEVELOPMENT v. GROUP MANAGEMENT CORPORATION

PANGANIBAN, J.

Appeals, dated December 29, 1994, dismissing the Petition for Annulment of Judgment filed by the petitioner LLDHC before the court a quo. But this is all academic now. The appellate court's decision had become final and executory on January 28, 1995."[7] (Emphasis ours) Jurisprudence mandates that when a decision becomes final and executory, it becomes valid and binding upon the parties and their successors in interest.[8] Such decision or order can no longer be disturbed or reopened no matter how erroneous it may have

GR No. 123893

2001-11-22

LUISITO PADILLA v. CA

QUISUMBING, J.

Without the trial court having acquired jurisdiction over petitioners, the latter could not be bound by the decision of the court. Execution can only be issued against a party and not against one who was not accorded his day in court.[14] To levy upon their properties to satisfy a judgment in a case in which they were not even parties is not only inappropriate; it most certainly is deprivation of property without due process of law.[15] This we cannot allow.

GR No. 114348

2000-09-20

NATIONAL IRRIGATION ADMINISTRATION v. CA

PARDO, J.

One who deals with property registered under the Torrens system is charged with notice of burdens and claims that are annotated on the title.[34]

GR No. 127797

2000-01-31

ALEJANDRO MILLENA v. CA

BELLOSILLO, J.

Petitioner also avers that he is an innocent purchaser for value and that an action for reconveyance cannot prosper against him. He argues that the finding of respondent appellate court of bad faith was not supported by evidence. A purchaser in good faith is one who buys property of another, without notice that some other person has a right to, or interest in, such property at the time of such purchase, or before he has notice of the claim or interest of some other persons in the property. Good faith, or the lack of it, is in the final analysis a question of intention; but in ascertaining the intention by which one is actuated on a given occasion, we are necessarily controlled by the evidence as to the conduct and outward acts by which alone the inward motive may, with safety, be determined. Truly, good faith is not a visible, tangible fact that can be seen or touched, but rather a state or condition of mind which can only be judged by actual or fancied tokens or signs. Otherwise stated, good faith is the opposite of fraud and it refers to the state of mind which is manifested by the acts of the individual concerned.[18]

	GR No. 149548 2009-12-04	ROXAS v. DAMBA-NFSW CARPIO MORALES, J.
The only recognized exceptions to the foregoing doctrine are the corrections of clerical errors or the making of the so-called nunc pro tunc entries, which cause no prejudice to any party, and, where the judgment is void.[75] Void judgments may be classified into two groups: those rendered by a court without jurisdiction to do so and those obtained by fraud or collusion.[76] None of these exceptions can be applied to the final and executory judgment of the Court of Appeals in CA-G.R. SP No. 36299.
	GR Nos. 162335 & 162605 2008-12-18	SEVERINO M. MANOTOK IV v. HEIRS OF HOMER L. BARQUE TINGA, J.
These petitions were referred to the Court en banc by the Special First Division which had initially ruled on them, most comprehensively in a Decision dated 12 December 2005.[4] They were accepted by the Court en banc in a Resolution dated 26 July 2006. Subsequently, the parties presented their various contentions before the Court in an oral argument held on 24 July 2007, followed by the submission of their respective memoranda. While the cases were under consideration of the Court en banc, the participation of the Office of the Solicitor General was required,[5] and a set of new parties was allowed leave to intervene.[6]
	GR NO. 151854 2008-09-03	PHILUX v. NLRC LEONARDO-DE CASTRO, J.
The decision in Legarda v. Court of Appeals[24] also invoked by petitioners, that the alleged reckless, inexcusable and gross negligence of counsel resulted in the deprivation of the client's property without due process of law, was modified on reconsideration in our en banc Resolution dated October 16, 1997.[25] The Court held:xxx as long as a party was given the opportunity to defend her interests in due course, she cannot be said to have been denied due process of law, for this opportunity to be heard is the very essence of due process. The chronology of events shows that the case took its regular course in the trial and appellate courts but Legarda's counsel failed to act as any ordinary counsel should have acted, his negligence every step of the way amounting to "abandonment, " in the words of the Gancayco decision. Yet, it cannot be denied that the proceedings which led to the filing of this case were not attended by any irregularity. The judgment by default was valid, so was the ensuing sale at public auction. If Cabrera was adjudged highest bidder in said auction sale, it was not through any machination on his part. All of his actuations that led to the final registration of the title in his name were aboveboard, untainted by any irregularity.
	GR No. 156078 2008-03-14	MARASIGAN v. MARASIGAN CHICO-NAZARIO, J.
As the Court of Appeals declared, due process is not a mantra, the mere invocation of which shall warrant a reversal of a decision. Well-settled is the rule that the essence of due process is the opportunity to be heard. In Legarda v. Court of Appeals,[46] the Court held that as long as parties to a case were given the opportunity to defend their interest in due course, they cannot be said to have been denied due process of the law. Neither do the records show any indicia that the preference of petitioners for the physical subdivision of the property was not taken into consideration by the Commissioners.
	GR No. 174219 2007-11-23	KLT FRUITS v. WSR FRUITS CHICO-NAZARIO, J.
As to the existence of a meritorious defense which warrants a further hearing of the case, KLT insist that the checks in question were forged[34] or stolen from the vault of KLT by Leopoldo Gonzales, and that Gonzales admitted that he was the author of the forgery and theft. The forgery and theft of the checks in question will prevent WSR from recovering from KLT the value of the said checks. It bears stressing, though, that the RTC did not give due credence to the claim of forgery by KLT that would insulate it from liability for the amount of the checks. All told, the instant case underwent a full-blown trial, in which both parties presented evidence including rebuttal and sur-rebuttal evidence. Where a party was given the opportunity to defend its interest in due course, it cannot be said to have been denied due process of law, for this opportunity to be heard is the very essence of due process.[35] It must be emphasized that KLT was adequately heard, and that all issues were ventilated before the Decision was promulgated. All the necessary pleadings were filed by KLT's counsel to protect its interests when the case was still before the RTC. KLT was not deprived of its day in court.[36] No denial of due process was shown. Verily, KLT was afforded adequate and full opportunity to ventilate its case in the proceedings below.
	GR NO. 158585 2005-12-13	AMON TRADING CORPORATION v. CA CHICO-NAZARIO, J.
Considering the vagaries of the case, private respondent brought the wrong upon itself. As adeptly surmised by the trial court, between petitioners and private respondent, it is the latter who had made possible the wrong that was perpetuated by Eleanor Sanchez against it so it must bear its own loss. It is in this sense that we must apply the equitable maxim that "as between two innocent parties, the one who made it possible for the wrong to be done should be the one to bear the resulting loss."[15] First, private respondent was the one who had reposed too much trust on Eleanor Sanchez for the latter to source its cement needs. Second, it failed to employ safety nets to steer clear of the rip-off. For such huge sums of money involved in this case, it is surprising that a corporation such as private respondent would pay its construction materials in advance instead of in credit thus opening a window of opportunity for Eleanor Sanchez or Lines & Spaces to pocket the remaining balance of the amount paid corresponding to the undelivered materials. Private respondent likewise paid in advance the commission of Eleanor Sanchez for the materials that have yet to be delivered so it really had no means of control over her. Finally, there is no paper trail linking private respondent to petitioners thereby leaving the latter clueless that private respondent was their true client. Private respondent should have, at the very least, required petitioners to sign the check vouchers or to issue receipts for the advance payments so that it could have a hold on petitioners. In this case, it was the representative of Lines & Spaces who signed the check vouchers. For its failure to establish any of these deterrent measures, private respondent incurred the risk of not being able to recoup the value of the materials it had paid good money for.
	GR NO. 161861 2005-03-11	SPS. WILLIAM AND JULIE LIM v. CHUATOCO TINGA, J.
Guided by previous decisions of this Court, good faith consists in the possessor's belief that the person from whom he received the thing was the owner of the same and could convey his title. Good faith, while it is always to be presumed in the absence of proof to the contrary, requires a well founded belief that the person from whom title was received was himself the owner of the land, with the right to convey it. There is good faith where there is an honest intention to abstain from taking any unconscientious advantage from another. Otherwise stated, good faith is the opposite of fraud and it refers to the state of mind which is manifested by the acts of the individual concerned.[17] Consistently, this Court has ruled that every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property. A person is charged with notice only of such burdens and claims as are annotated on the title.[18] Thus, where there is nothing in the certificate of title to indicate any cloud or vice in the ownership of the property, or any encumbrance thereon, the purchaser is not required to explore further than what the Torrens Title upon its face indicates in quest for any hidden defects or inchoate right that may subsequently defeat his right thereto.[19]
	GR No. 141145 2004-11-12	REPUBLIC v. WILSON P. ORFINADA SANDOVAL-GUTIERREZ, J.
In Legarda vs. Court of Appeals,[10] we sustained the buyer's right to rely on the correctness of the certificate of title, thus:"If a person purchases a piece of land on the assurance that the seller's title thereto is valid, she should not run the risk of being told later that her acquisition was ineffectual after all. If we were to void a sale of property covered by a clean and unencumbered torrens title, public confidence in the Torrens System would be eroded and land transactions would have to be attended by complicated and inconclusive investigations and uncertain proof of ownership. The consequence would be that land conflicts could proliferate and become more abrasive, if not even violent."
	GR No. 156580 2004-06-14	LUZ DU v. STRONGHOLD INSURANCE CO. PANGANIBAN, J.
If either the third-party claim or the subsequent registration of the prior sale was insufficient to defeat the previously registered attachment lien, as ruled by the Court in Capistrano, it follows that a notice of lis pendens is likewise insufficient for the same purpose. Such notice does not establish a lien or an encumbrance on the property affected.[18] As the name suggests, a notice of lis pendens with respect to a disputed property is intended merely to inform third persons that any of their transactions in connection therewith -- if entered into subsequent to the notation -- would be subject to the result of the suit.
	GR No. 141407 2002-09-09	LAPULAPU DEVELOPMENT v. GROUP MANAGEMENT CORPORATION PANGANIBAN, J.
Appeals, dated December 29, 1994, dismissing the Petition for Annulment of Judgment filed by the petitioner LLDHC before the court a quo. But this is all academic now. The appellate court's decision had become final and executory on January 28, 1995."[7] (Emphasis ours) Jurisprudence mandates that when a decision becomes final and executory, it becomes valid and binding upon the parties and their successors in interest.[8] Such decision or order can no longer be disturbed or reopened no matter how erroneous it may have
	GR No. 123893 2001-11-22	LUISITO PADILLA v. CA QUISUMBING, J.
Without the trial court having acquired jurisdiction over petitioners, the latter could not be bound by the decision of the court. Execution can only be issued against a party and not against one who was not accorded his day in court.[14] To levy upon their properties to satisfy a judgment in a case in which they were not even parties is not only inappropriate; it most certainly is deprivation of property without due process of law.[15] This we cannot allow.
	GR No. 114348 2000-09-20	NATIONAL IRRIGATION ADMINISTRATION v. CA PARDO, J.
One who deals with property registered under the Torrens system is charged with notice of burdens and claims that are annotated on the title.[34]
	GR No. 127797 2000-01-31	ALEJANDRO MILLENA v. CA BELLOSILLO, J.
Petitioner also avers that he is an innocent purchaser for value and that an action for reconveyance cannot prosper against him. He argues that the finding of respondent appellate court of bad faith was not supported by evidence. A purchaser in good faith is one who buys property of another, without notice that some other person has a right to, or interest in, such property at the time of such purchase, or before he has notice of the claim or interest of some other persons in the property. Good faith, or the lack of it, is in the final analysis a question of intention; but in ascertaining the intention by which one is actuated on a given occasion, we are necessarily controlled by the evidence as to the conduct and outward acts by which alone the inward motive may, with safety, be determined. Truly, good faith is not a visible, tangible fact that can be seen or touched, but rather a state or condition of mind which can only be judged by actual or fancied tokens or signs. Otherwise stated, good faith is the opposite of fraud and it refers to the state of mind which is manifested by the acts of the individual concerned.[18]

VICTORIA LEGARDA v. CA