Title
Agustino vs. Court of Appeals
Case
G.R. No. L-46955
Decision Date
Feb 27, 1989
A 1926 homestead sale violated a 5-year prohibition, rendering it void. Heirs reclaimed land; laches overruled, void contract upheld, reimbursement ordered.
Font Size:

Case Digest (G.R. No. L-46955)

Facts:

  1. Background of the Land:
    The case involves a three-hectare parcel of land, part of a sixteen-hectare homestead originally covered by Original Certificate of Title (OCT) No. 597, issued in 1925 under Commonwealth Act No. 141 (Homestead Law) in favor of Ambrocio Loren.

  2. Initial Sale and Prohibition:
    In 1926, Ambrocio Loren sold the land to Gavino Luarca for P150.00. This sale occurred within the 5-year prohibition period under the Homestead Law, making it void ab initio. Luarca took possession of the land and sold it to private respondents Severino Moldogo and Catalina Mercene in 1937 for P180.00. Both deeds of sale were unregistered.

  3. Heirs' Claim:
    In 1958, the heirs of Ambrocio Loren (petitioners Consorcia Teodoro and Ernesto Agustino) executed an affidavit of adjudication and obtained Transfer Certificate of Title (TCT) No. 7894, covering the disputed land. They demanded P500.00 per hectare from the private respondents, who refused to pay.

  4. Subsequent Transactions:
    The petitioners sold portions of the land to other parties, and in 1967, they sold a portion (including the disputed 3 hectares) to co-petitioners Benito Villavicencio and Corazon Sotto. TCT No. 31676 was issued in their favor. The private respondents were ousted from the land, prompting them to file an action for recovery of possession with damages.

  5. Trial Court Decision:
    The trial court awarded Parcel B (1 hectare) to the private respondents but awarded Parcel A (3 hectares) to the petitioners, ruling that the 1926 sale was void due to the 5-year prohibition.

  6. Appellate Court Decision:
    The Court of Appeals reversed the trial court's decision regarding Parcel A, awarding it to the private respondents based on the equitable principle of laches, as the petitioners had been inactive from 1926 to 1958.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Void Contract:
    The sale of the homestead by Ambrocio Loren to Gavino Luarca in 1926 was void ab initio because it violated the 5-year prohibition under Commonwealth Act No. 141. A void contract cannot be ratified or validated by the passage of time.

  2. Equity Follows the Law:
    The equitable principle of laches cannot be invoked to override clear provisions of law based on public policy. Courts cannot use equity to validate a void contract.

  3. Doctrine of Pari Delicto:
    The doctrine of pari delicto (both parties equally at fault) does not apply in this case because the homestead law is designed to protect the homesteader and their family. Public policy allows the heirs to recover the land despite the illegal sale by their predecessor.

  4. Innocent Purchasers for Value:
    The petitioners Villavicencio and Sotto cannot claim to be innocent purchasers for value because the private respondents had already annotated their adverse claim on the title before the sale.

  5. Reimbursement:
    While the petitioners are entitled to the land, they must reimburse the private respondents for the P150.00 paid by Loren in 1926, as equity demands.

  6. Government's Role:
    The decision is without prejudice to the government's right to initiate reversion proceedings if the petitioners fail to comply with the homestead law's requirements.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.