G.R. No. 224720-23 - Martel vs. People

Respondent Cristina B. Bombaes owned Lot No. 782 in Roxas City, originally covered by TCT No. T-41765.
On March 17, 2008, respondent mortgaged the property to Vicente Atlas Catalan to secure a loan amounting to P1,350,000.00 with 5% monthly interest.
When respondent defaulted on the loan, a Deed of Absolute Sale was executed on October 19, 2009, transferring the subject lot to Catalan.
The property's title was subsequently transferred to Catalan under TCT No. T-58922 on November 26, 2009.

On April 9, 2010, petitioner Ma. Kristel B. Aguirre offered to purchase Lot No. 782 from Catalan.
Catalan agreed, and the parties executed a Deed of Conditional Sale on the same day, followed by a Deed of Absolute Sale on May 4, 2010 upon petitioner’s full payment.
The property was registered in petitioner’s name under TCT No. 097-2010000326.

Respondent filed a complaint for quieting of title before the RTC, alleging that Catalan coerced her into a simulated sale to facilitate his plan to mortgage the property and apply the proceeds to her unpaid loan obligation.
Respondent also claimed that a deed of assignment was executed between her and Catalan to secure her right to redeem the property.
Catalan, on the other hand, asserted that the arrangement was temporary and intended to secure funds for his political campaign, emphasizing the presence of additional documents (acknowledgment receipt and deed of confirmation) evidencing the sale.

The Regional Trial Court (RTC) dismissed respondent’s complaint for quieting of title on October 24, 2012, finding the Deed of Absolute Sale (October 19, 2009) valid and notarized.
The RTC recognized petitioner as a bona fide purchaser for value, noting that the title presented (TCT No. T-58922) was clean and free of adverse claims at the time of her purchase.
On appeal, the CA initially affirmed the RTC decision on May 31, 2016 but modified it by deleting the moral damages awarded to Catalan.

Respondent filed a Motion for Reconsideration with the CA, asserting that the Deed of Absolute Sale of October 19, 2009 was void and that petitioner was not an innocent purchaser in good faith.
The CA, in its Amended Decision dated January 20, 2017, reversed its earlier ruling by declaring the Deed of Absolute Sale (October 19, 2009) void on the ground that it was simulated and only intended to facilitate a mortgage transaction.
The CA further ruled that petitioner was not an innocent purchaser because an adverse claim was annotated on the title on May 12, 2010 — eight days after the sale — which constituted sufficient notice.
Petitioner’s subsequent motion for reconsideration was denied by the CA in a Resolution dated June 30, 2017, prompting the filing of the present Petition for Review on Certiorari.

Whether respondent’s Motion for Reconsideration of the CA Decision dated May 31, 2016 was properly and timely filed, despite the contention regarding a belated filing.

Whether petitioner Ma. Kristel B. Aguirre qualifies as an innocent purchaser in good faith and for value, considering the claims that the Deed of Absolute Sale was simulated and that an adverse claim had been annotated on the title.