Title
Alamayri vs. Pabale
Case
G.R. No. 151243
Decision Date
Apr 30, 2008
Dispute over land sale validity; petitioner claims seller's incompetence, but Court upholds 1984 sale to respondents, ruling guardianship findings non-retroactive and insufficient evidence of incapacity.
Font Size:

Case Digest (G.R. No. 151243)

Facts:

Background of the Case:
This case involves a dispute over a parcel of land in Calamba, Laguna, covered by Transfer Certificate of Title (TCT) No. T-3317 (27604). The petitioner, Lolita R. Alamayri, seeks to reverse the Court of Appeals' decision upholding the validity of a Deed of Absolute Sale executed by Nelly S. Nave in favor of the respondents, the Pabale siblings.

Initial Contract to Sell:
On January 3, 1984, Nelly S. Nave entered into a handwritten "Kasunduan Sa Pagbibilihan" (Contract to Sell) with Sesinando M. Fernando, representing S.M. Fernando Realty Corporation, involving the subject property. However, Nave later refused to accept the partial down payment from Fernando, claiming she did not want to sell the property to him anymore.

Filing of the Complaint:
Fernando filed a Complaint for Specific Performance with Damages against Nave on February 6, 1984, before the Regional Trial Court (RTC) of Calamba, Laguna. Nave, in her defense, stated that she had already sold the property to the Pabale siblings on February 20, 1984, and that she was not fully aware of the nature of the document she signed with Fernando.

Motion to Dismiss and Intervene:
Nave filed a Motion to Dismiss, asserting that she could not be compelled to execute a Deed of Sale in favor of Fernando. The Pabale siblings filed a Motion to Intervene, claiming ownership of the property. The trial court denied Nave's Motion to Dismiss and allowed the Pabale siblings to intervene.

Amended Answers and Counterclaims:
Nave filed an Amended Answer, alleging undue influence and fraud, and later filed a Second Amended Answer, claiming incapacity to contract due to mental deficiency. The trial court denied her Second Amended Answer.

Guardianship Proceedings:
In 1987, Atty. Vedasto Gesmundo, Nave’s husband, filed a Petition for Guardianship over Nave, alleging her incompetence. The RTC declared Nave incompetent and appointed a guardian for her estate. Nave died in 1992, and Gesmundo executed an Affidavit of Self-Adjudication for her inherited properties.

Trial Court Decision:
The RTC declared both the Contract to Sell with Fernando and the Deed of Absolute Sale with the Pabale siblings null and void, and ordered the reconveyance of the property to Alamayri, who claimed to have acquired the property from Gesmundo.

Appeal to the Court of Appeals:
The Court of Appeals reversed the RTC decision, upholding the validity of the Deed of Absolute Sale in favor of the Pabale siblings. Alamayri filed a Motion for Reconsideration, which was denied.

Issue:

  1. Whether the Court of Appeals erred in holding that Nave’s incompetence, as declared in the guardianship proceedings, cannot retroactively affect the validity of the Deed of Sale executed in 1984.
  2. Whether the Court of Appeals erred in holding that the decision in the guardianship proceedings is not binding on the Pabale siblings.
  3. Whether the Court of Appeals erred in denying Alamayri’s Motion to Schedule Hearing to Mark Documentary Exhibits to establish the identity of Jose Pabale as the father of the Pabale siblings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court affirmed the Court of Appeals' decision, upholding the validity of the 1984 Deed of Absolute Sale in favor of the Pabale siblings. The Court ruled that the guardianship proceedings did not retroactively invalidate the sale, and that Alamayri failed to prove Nave’s incompetence at the time of the transaction. The Court stressed the importance of proper procedure and the burden of proof in establishing incapacity in contractual agreements.


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.