Anastacio Tingalan vs.

Spouses Melliza
G.R. No. 195247, 29 June 2015

Petitioner is the original owner under a free patent. He executed a DOS over the property
within the 5 year prohibition period. However, buyer has been in actual exclusive possession,
Duplicate Certificate of Title and Tax Declaration were also issued under their names. Around
23 years later, Elena filed an adverse claim over the subject property. Petitioner countered and
demanded that respondent vacate the property, but the latter refused claiming ownership over
the same as supported by the Deed. WON petitioner is barred by laches and WON the
prohibition makes a distinction between executory and consummated sale. The prohibition
does not distinguish between executory and consummated sales; being void, it produces no
legal effect. It could not transfer title to the subject property; there could be no basis for the
issuance of a title from petitioner Anastacios name to the names of respondent-spouses. The
action for the declaration of its absolute nullity is imprescriptible.

Julie S. Sumbilla vs. Matrix Finance Corporation

G.R. No. 197582, 29 June 2015

Petitioner was convicted for violation of BP22 however the penalty was
allegedly in violation of existing law. The decision was already final and she
filed a certiorari instead asking for liberal application of procedure. WON
immutability of judgment applies. Immutability is not a hard and fast rule.
The Court has the power and prerogative to suspend its own rules and to
exempt a case from their operation if and when justice requires it. Procedural
rules were conceived to aid the attainment of justice. If a stringent
application of the rules would hinder rather than serve the demands of
substantial justice, the former must yield to the latter. The penalty imposed is
obviously out of range of that prescribed by law which is fine may be double
the amount of the face value of the rubber check which in no case should
exceed P200,000.00. What was imposed is more than 11 times the value.