Title
AFP Retirement and Separation Benefits System vs. Plastic King Industrial Corp.
Case
G.R. No. 231395
Decision Date
Jun 26, 2023
AFP-RSBS bought property from Flavianos; Plastic King claimed prior sale rights. Court ruled Plastic King owned the land; AFP-RSBS was not a buyer in good faith and title canceled.
A

Case Digest (G.R. No. 231395)

Facts:

  • Parties and contractual relations
    • Atty. Nilo J. Flaviano, representing himself and as attorney-in-fact of co-owners Johanna Flaviano, Carlito Flaviano, Nelia Flaviano, and Letecia Flaviano, owned a property Lot Y-2-C in General Santos City.
    • On August 8, 1995, they executed an Exclusive Contract to Sell the property authorizing Evelyn Te and Alan Fausto V. Posadas to find a buyer.
    • Evelyn offered the property to Plastic King Industrial Corporation, represented by Merlen Agabin.
    • The Flavianos, through Atty. Flaviano, transferred rights over Lot Y-2-C to Plastic King by a "Transfer of Rights" for PHP 500,000 and warranted peaceful possession and ownership.
    • On August 30, 1995, another Transfer of Rights was executed for the foreshore area.
    • A "Deed of Undertaking" was executed, obligating titling in favor of Plastic King within six months.
    • Memorandum of Agreement between Flaviano and Plastic King set the purchase price at PHP 15.2 million with a PHP 3 million downpayment.
  • Subdivision and titling issues
    • The property was subdivided into three lots: Y-2-C-1, Y-2-C-2, Y-2-C-3 with Original Certificates of Title (OCTs) issued in the names of Flaviano family members, not Plastic King.
    • Plastic King demanded deed of conveyance, but Flaviano did not comply.
  • Second sale to AFP-RSBS
    • Negotiations between AFP-RSBS and Flavianos commenced, with DENR issuing new Sales Patents on December 9, 1996.
    • Contract to Sell and Amended Contract to Sell executed between AFP-RSBS and Flavianos totaling PHP 40,010,000.
    • Deed of Absolute Sale executed on March 4, 1997 conveying the lots to AFP-RSBS, warranting valid titles and peaceful possession.
    • AFP-RSBS asserts it checked the Register of Deeds: titles were clean before purchase.
  • Plastic King's legal action and notice
    • Plastic King filed suit on March 12, 1997, for specific performance and injunction against Flavianos to restraint disposal, alleging property already sold to them.
    • Plastic King informed AFP-RSBS via phone calls and letter about the prior sale and notice of lis pendens on titles.
    • AFP-RSBS fully paid purchase price by February 28, 1997; new Transfer Certificates of Title (TCTs) were issued in AFP-RSBS's name on March 17, 1997.
  • Flavianos' defense and counterclaims
    • Flavianos denied sale to Plastic King, alleging the "Transfer of Rights" was a forgery.
    • Claimed revocation of prior sale via a "Memorandum of Revocation" signed by Evelyn, claiming full refund.
    • Flavianos also filed a Third-Party Complaint against Evelyn, alleging she did not remit refunds to Plastic King.
  • Court proceedings and rulings
    • Judge Carpio, who initially heard the case, inhibited himself due to personal connection.
    • Case was re-raffled and eventually decided by Judge Robillo.
    • Trial court ruled for Plastic King, ordering Flavianos to deliver possession and titles, cancelling AFP-RSBS titles as void, and ordering reimbursement to AFP-RSBS.
    • Court of Appeals affirmed the trial court decision.

Issues:

  • Was Judge Carpio's voluntary inhibition proper and did it affect the validity of the judgment by Judge Robillo?
  • Was the revocation of the contract of sale executed through agent Evelyn Te valid?
  • Was AFP-RSBS an innocent purchaser in good faith and for value entitled to protection?
  • Was the cancellation of the Transfer Certificates of Title in AFP-RSBS's name proper?
  • Are Flavianos bound to deliver the lots and refund AFP-RSBS the purchase price?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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