G.R. No. 223810 - Robles vs. People

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G.R. No. 223810: Robles vs. People

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Title Supreme Court: Abuyo vs. De Suazo

Case: G.R. No. L-21202

Decision Date: Oct 29, 1966

Heirs challenged an unrecorded 1939 land sale; Supreme Court upheld its validity, ruling heirs bound as privies, denying recovery of disputed land.

unrecorded deed of sale

A

Case Digest (G.R. No. 223810)
Standard Advanced

Facts:

Ownership and Sale of the Land:

The original owner of the almost 10-hectare land in Lanote, Isabela, Basilan City, was Ambrosio Abuyo, the father of the plaintiffs-appellants, Leonardo Abuyo. The land was covered by Original Certificate of Title No. 814.
On May 8, 1939, Ambrosio Abuyo sold a 3-hectare portion of the land to Gregorio Suazo, the husband of the defendant-appellee, Concepcion B. de Suazo.
Ambrosio Abuyo passed away on May 28, 1946.

Possession and Use of the Disputed Land:

After the sale, Gregorio Suazo and his wife, Concepcion B. de Suazo, took possession of the 3-hectare portion. They fenced the land, paid taxes, and enjoyed its fruits.
The defendant has maintained possession of the land up to the present.

Legal Proceedings:

The plaintiffs filed a suit to recover the 3-hectare portion, claiming ownership.
The lower court ruled in favor of the defendant, and the plaintiffs appealed directly to the Supreme Court.

Plaintiffs' Argument:

The plaintiffs questioned the authenticity of the deed of sale dated May 8, 1939, and argued that it was not binding on them because it was unrecorded.

Issues:

Whether the plaintiffs can challenge the factual findings of the lower court regarding the authenticity of the deed of sale.
Whether the unrecorded deed of sale is binding on the plaintiffs, who are the heirs of the original owner, Ambrosio Abuyo.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Conclusion:

The Supreme Court affirmed the lower court's judgment in favor of the defendant, holding that the unrecorded deed of sale was valid and binding on the plaintiffs. The plaintiffs were ordered to pay the costs of the suit.

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