G.R. No. 121703 ; November 29, 2001
NATIVIDAD T. TANGALIN, petitioner, vs. COURT OF APPEALS, DR. RAMON L. COCSON, JOSEFINA G. COCSON, EDITHA G. TIGLAO, FE F. GOMEZ, and ATTY. PEDRO F. MARTINEZ, respondents.

FACTS

Spouses Ramon and Josefina Cocson obtained a loan from Atty. Pedro Martinez in 1970, secured by a mortgage over two parcels of land. Upon default, Martinez extrajudicially foreclosed the properties and purchased them at auction in 1971. Subsequently, in 1972, the Cocsons executed a separate Deed of Absolute Sale covering different parcels of land in favor of Martinez. In 1975, Martinez sold one of these properties from the 1972 sale to Natividad Tangalin. The Cocsons then filed a complaint to annul all sales, including the one to Tangalin. The trial court declared the 1972 sale void but upheld Tangalin’s purchase as made in good faith and for value. The Court of Appeals affirmed this ruling.
The petitioner, Natividad Tangalin, assails the Court of Appeals’ decision, arguing it erred in ruling on the validity of her purchase from Martinez. She contends that since the Cocsons’ appeal was dismissed for non-payment of docket fees, the trial court’s declaration that she was a buyer in good faith had become final and could no longer be reviewed. She asserts the appellate court exceeded its jurisdiction by modifying this aspect of the trial court’s judgment.

ISSUE

Whether the Court of Appeals erred in reviewing and affirming the trial court’s finding that Natividad Tangalin was a buyer in good faith, despite the dismissal of the Cocsons’ appeal.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The appellate court did not err in reviewing the issue of Tangalin’s status as a buyer in good faith. While the Cocsons’ appeal was dismissed, the appeal of Atty. Martinez remained pending. Martinez’s appeal necessarily placed the entire case, including the validity of the subsequent sale to Tangalin, within the appellate court’s jurisdiction. The issue of whether Tangalin was a purchaser in good faith was the lis mota or pivotal point for determining the validity of the prior 1972 sale from the Cocsons to Martinez, which was directly challenged in Martinez’s appeal.
It is a settled rule that appellate courts have the authority to rule on matters not specifically assigned as errors if they are indispensable or necessary to the just resolution of the pleaded issues. The validity of Tangalin’s purchase was inextricably linked to the core issue of the validity of Martinez’s title, which he derived from the 1972 sale. Therefore, the Court of Appeals acted correctly within its discretionary power to review this indispensable matter to render a complete and equitable judgment. The finding that Tangalin was a buyer in good faith and for value stands.