Case Digest (G.R. No. 177549) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leonardo Acabal and Ramon Nicolas v. Villaner Acabal et al., decided on March 31, 2005, the late Alejandro Acabal and Felicidad Balasabas transferred an 18.15-hectare parcel in Barrio Tanglad, Manjuyod, Negros Oriental, to their son Villaner Acabal by Deed of Absolute Sale dated July 6, 1971. After becoming a widower, Villaner purportedly executed on April 19, 1990 a Deed of Absolute Sale conveying the same land to his nephew-godson Leonardo Acabal for ₱10,000. Leonardo then sold the property to Ramon Nicolas on May 19, 1990. Villaner later filed for annulment of these deeds, claiming he had in fact signed a Lease Contract for three years at ₱1,000 per hectare and was deceived into signing the sale documents. At trial, Villaner denied reading or notarizing the deed of sale, alleged forgery of witness signatures, and contended the sale price was grossly inadequate. The Regional Trial Court dismissed his complaint, but the Court of Appeals reversed, finding the sale simulated. Case Digest (G.R. No. 177549) Expanded Legal Reasoning Model
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)