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Mandatory Pre-Trial in Alarcon Case

1) Roberto Alarcon filed a complaint to nullify the sale of his land by his father to Bienvenido Juani, Edgardo Sulit, and Virginia Baluyot, arguing the sale contract signature was forged, there was no consideration, and his father no longer had authority to sell the land. 2) During pre-trial, the parties admitted facts that led the trial court to declare the sale contract void and order the cancellation of the buyers' title certificates. 3) The Court of Appeals later annulled the trial court's decision, but the Supreme Court reinstated it, holding that pre-trial is mandatory and the buyers could not claim being denied their day in

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162 views1 page

Mandatory Pre-Trial in Alarcon Case

1) Roberto Alarcon filed a complaint to nullify the sale of his land by his father to Bienvenido Juani, Edgardo Sulit, and Virginia Baluyot, arguing the sale contract signature was forged, there was no consideration, and his father no longer had authority to sell the land. 2) During pre-trial, the parties admitted facts that led the trial court to declare the sale contract void and order the cancellation of the buyers' title certificates. 3) The Court of Appeals later annulled the trial court's decision, but the Supreme Court reinstated it, holding that pre-trial is mandatory and the buyers could not claim being denied their day in

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MK
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© © All Rights Reserved
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RULE 18 PRE-TRIAL

Alarcon v. CA, 323 SCRA 716 (2000)

TOPIC: Pre-trial

FACTS: Before leaving to work in Brunei, Roberto G. Alarcon left with his father, Tomas
Alarcon, an SPA to administer, mortgage or sell his properties in Baliwag, Bulacan. His father
allegedly sold to Bienvenido Juani, Edgardo Sulit and Virginia Baluyot a portion of his land
containing an area of 2,500 sq. m. for a nominal consideration of P5,000.00, and titles were
transferred in the latter's names. Roberto filed a complaint praying for the nullification of the
sale contending that: (1) his father's signature on the Deed of Sale was forged; (2) there was
no consideration of the sale; and (3) his father had no more authority to sell the land since the
special power of attorney had already been earlier revoked.

RTC: The parties made some admissions of facts during the pre-trial conference. The partial
decision declared that the deed of sale in favor of the defendants was void ab initio, hence,
the TCT issued to the defendants were null and void. The trial court also ordered the Register
of Deeds of Malolos to cancel the certificates of title of the defendants. Roberto moved for the
execution of the partial decision which was granted by the trial court. Defendants failed to
interpose an appeal from the partial decision, the same became final and executory. However,
judgment could not be executed because the defendants refused to surrender their respective
Owner's Duplicate of the TCT's.

CA: After several years, respondent filed with the Court of Appeals a petition for the
annulment of the trial court's partial decision. After hearing the case, the Court of Appeals
granted the petition and set aside the partial decision. The CA ruled that the partial decision
was vitiated by extrinsic fraud.

ISSUE: Whether or not a pre-trial is mandatory before hearing any case

HELD: The rules have made mandatory that a pre-trial should first be conducted before
hearing any case. The parties themselves are required to attend or their representative with
written authority from them in order to arrive at a possible amicable settlement, to submit to
alternative modes of dispute resolution, and to enter into stipulations or admissions of facts
and documents. All of the matters taken up during the pre-trial, including the stipulation of
facts and the admissions made by the parties are required to be recorded in a pre-trial order.
The Supreme Court ruled that on the basis of the clear admissions made by the parties
in the case at bar, the partial decision was rendered. Juani cannot now claim that he was
denied his day in court when judgment was rendered on the basis of their counsel's
admissions. Since it was patent that the deed of sale was a forgery, no parcel of land was
transferred to the vendees. Thus, the TCTs issued were null and void. Respondent Court,
therefore, committed a reversible error in giving due course to the petition filed before it, the
same not being based on extrinsic fraud and was barred by prescription. The partial decision
rendered by the Regional Trial Court was reinstated.

The petition is GRANTED.

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