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### Facts:
1. **Background of the Maysilo Estate:** The property involved was part of the Maysilo Estate left by Gonzalo Tuason, originally covering 1,660.26 hectares across Caloocan City, Valenzuela, and Malabon. The estate was subdivided into smaller lots covered by five mother titles, including Original Certificate of Title (OCT) No. 994.
2. **Heirs’ Initial Petitions:** On September 27, 1961, petitioners claiming to be the heirs of Maria de la Concepcion Vidal filed a petition with the Court of First Instance (CFI) of Rizal for substitution of their names on OCT No. 994. The CFI granted this petition. They followed with a petition for partition and accounting of the Maysilo Estate; the RTC appointed commissioners for equitable division but received no recommendation.
3. **Conflicting Titles and Sales:** Multiple cases arose over the estate due to two dates of registration for OCT No. 994 (April 19, 1917, and May 3, 1917). Estrella et al. sued in 2006 for the nullification of Transfer Certificate of Title (TCT) No. 326321 against Gotesco Investment, Inc., claiming they were the rightful heirs who never sold the subject property.
4. **Tri-City Landholdings, Inc.’s Involvement:** In 2016, Tri-City filed to intervene, claiming an assignment of the subject property. The RTC allowed this but denied Gotesco’s motion to dismiss.
5. **SM Prime Holdings’ Substitution and Motions:** SM Prime moved to substitute Gotesco after purchasing the property. It opposed Tri-City’s intervention and moved for outright dismissal, arguing previous dissolution of OCT No. 994 dated April 19, 1917.
6. **RTC and CA Proceedings:** The RTC dismissed Estrella et al.’s complaint and Tri-City’s complaint-in-intervention. The ad court confirmed Estrella et al.’s appeal abandonment due to failure to file an appellant’s brief, leading to a dismissal.
7. **Petitions to the Supreme Court:** Estrella et al. and Tri-City filed petitions challenging the CA’s decisions, focusing on procedural fairness and their asserted rights to the property.
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### Issues:
1. **Procedural Infirmities in G.R. No. 257814:** Whether procedural defects in the petition warrant its outright dismissal.
2. **CA’s Dismissal of Estrella et al.’s Appeal:** Whether the Court of Appeals correctly dismissed the appeal due to the late filing of the appellant’s brief.
3. **Independence of Tri-City’s Intervention:** Whether Tri-City’s intervention can proceed as an independent action.
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### Court’s Decision:
1. **Procedural Infirmities – G.R. No. 257814:**
– The Supreme Court acknowledged multiple procedural defects including lack of service proof, illegible order copies, and absence of a competent identity affidavit by the counsel.
– Estrella et al. did not provide verifiable material dates indicating the timely filing of the petition.
– Filing through private courier instead of registered mail was considered unacceptable for initiatory pleadings, leading to a late filing date.
– The Petition was ultimately dismissed due to these procedural failures.
2. **Dismissal of Appeal by the CA:**
– Estrella et al. failed to submit their appellant’s brief within the permissible period, leading the CA to dismiss the appeal.
– The Supreme Court found that the CA acted within its authority and considered the brief’s late filing as an abandonment of the appeal.
– The Court noted that negligence by counsel binds the client, except in cases involving gross negligence denying due process or resulting in loss of a substantial right, none of which were found here.
3. **Tri-City’s Intervention:**
– The Supreme Court held that intervention cannot proceed independently as it is ancillary and supplemental to the main action.
– Since the main action was dismissed, Tri-City’s intervention was also dismissed.
– The Court stated that intervention must relate to an ongoing principal litigation.
4. **Counsel’s Misrepresentation:**
– Atty. Mario Bernardo S. Cerro was ordered to explain why he should not face disciplinary actions for submitting an inaccurate affidavit of service.
### Doctrine:
1. **Procedural Compliance:** Compliance with procedural rules is essential for the validity of appeals; failure to comply can result in outright dismissal.
2. **Abandonment and Timeliness:** Failure to timely file necessary documents, such as an appellant’s brief, can be deemed an abandonment of the appeal.
3. **Independence of Intervention:** Intervention is not an independent cause of action and must tie into an existing primary suit; ancillary actions cannot persist without a primary suit.
4. **Professional Responsibility:** Misrepresentation by counsel can lead to administrative sanctions to uphold the integrity of the judicial process.
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### Class Notes:
– **Procedural Rules:** Strict adherence to procedural requirements, such as the proper service of documents and timely filings, is crucial. Non-compliance has severe consequences, including dismissal of the appeal.
– **Appellant’s Responsibility:** The burden of timely filing an appellant’s brief lies with the appellant. Counsel’s negligence generally binds the client unless exceptions of grievous negligence apply.
– **Intervention Limitation:** Interventions must be connected to an existing primary case and cannot proceed independently if the primary suit is dismissed.
– **Legal Malpractice:** Attorneys must ensure accurate and truthful submissions; lapses can result in disciplinary proceedings.
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### Historical Background:
– **Maysilo Estate Case Background:** The case is an extension of the long-standing disputes over the Maysilo Estate, involving contradictory claims and titles from transactions dating back to the early 20th century.
– **Legacy of Litigation:** The controversial nature of OCT No. 994 has led to numerous lawsuits, reflecting chronic challenges in estate partitions and conflicting titles in the Philippine legal system.
– **Impact of Precedents:** Previous Supreme Court rulings clarifying the validity of OCT No. 994 established jurisprudence that influenced the outcomes in related cases, reinforcing the binding nature of res judicata and judicial consistency.
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