Title
Acabal vs. Acabal
Case
G.R. No. 148376
Decision Date
Mar 31, 2005
Dispute over 18.15-hectare land: Villaner claimed lease, Leonardo asserted sale. SC ruled sale valid for Villaner's 5/9 share, no fraud, adequate price, no CARL violation.

Case Digest (G.R. No. 177549)
Expanded Legal Reasoning Model

Facts:

  • Background and ownership
    • Respondent Villaner Acabal’s parents sold an 18.15-hectare parcel in Manjuyod, Negros Oriental to him by Deed of Absolute Sale dated July 6, 1971 for ₱2,000.
    • On April 19, 1990, Villaner executed a document in favor of his godson/nephew Leonardo Acabal concerning the same land.
  • Disputed document and trial proceedings
    • Villaner later alleged that the April 19, 1990 instrument was a three-year Lease Contract at ₱1,000 per hectare, witnessed by employees of Judge Villegas, and not a sale.
    • Leonardo produced the same instrument as a Deed of Absolute Sale for ₱10,000, prepared by Carmelo Cadalin and witnessed by Cadalin and his wife.
    • Villaner filed suit on October 11, 1993, for annulment of the deeds of sale; at trial he claimed deception and lack of consent.
  • Procedural history
    • The Regional Trial Court dismissed Villaner’s complaint, upholding the sale in favor of Leonardo and Ramon Nicolas.
    • The Court of Appeals reversed, declaring the sale simulated and fictitious and awarding respondents rental.
    • Petitioners Leonardo Acabal and Ramon Nicolas filed a Petition for Review on Certiorari before the Supreme Court.

Issues:

  • Did the Court of Appeals err in not applying Rule 8, Section 8 of the Rules of Court when Villaner failed to deny the genuineness and due execution of the deed under oath?
  • Was Villaner deceived into signing the Deed of Absolute Sale, thus vitiating his consent?
  • Was the ₱10,000 consideration grossly inadequate in light of the fair market value of the property in 1990?
  • Did petitioners qualify as buyers in good faith, and did Villaner’s delay in challenging their possession bar his action?
  • Did the sale violate the agrarian reform retention limits under Republic Act No. 6657?
  • As co-owners and heirs of Villaner’s deceased wife, were the other heirs bound by or entitled to consent to the sale of the conjugal property?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.