Case Digest (G.R. No. 165943)
Facts:
The case involves Eliodoro Aleligay, substituted by his son Ceferino Aleligay, as the petitioner against respondents Teodorico Laserna, Priscilla Villagracia, and Angustia Villagracia. The events leading to this case began with a 124,554 square meter parcel of land located in the Barrios of Daplas and Matagnop, Dao, Capiz, originally owned by Anselmo Aleligay, who passed away in 1927. Upon his death, the property was inherited by his heirs, including Eliodoro. In 1946, Eliodoro mortgaged the property to Teodorico Laserna but retained possession. Eliodoro later discovered a deed of sale allegedly signed by him in favor of Laserna, which he claimed was a forgery. Laserna, on the other hand, contended that he had purchased the property from Eliodoro and his siblings in 1946, and later sold it to the Villagracias in 1969. The Regional Trial Court (RTC) of Roxas City, Branch 18, dismissed Eliodoro's complaint for lack of cause of action on Ma...
Case Digest (G.R. No. 165943)
Facts:
Ownership and Inheritance
- The subject of the controversy is a 124,554 sq. m. parcel of land (Lot No. 1235) located in Dao, Capiz, originally owned by Anselmo Aleligay.
- Upon Anselmo's death in 1927, the land passed to his heirs: Eleno, Maura, Juan, Consolacion, Rosario, and petitioner Eliodoro Aleligay (now deceased, substituted by his son Ceferino Aleligay).
Mortgage and Alleged Sale
- In 1946, Eliodoro Aleligay mortgaged the property to respondent Teodorico Laserna but retained possession.
- Eliodoro claimed he attempted to redeem the property several times but was persuaded by Laserna not to hurry.
- In 1976, Eliodoro discovered a deed of sale in favor of Laserna, allegedly signed by him, but he claimed his signature was forged.
- Laserna later sold the property to respondents Priscilla and Angustia Villagracia, who secured Original Certificate of Title (OCT) No. 0-995.
Contention of the Parties
- Eliodoro's Claim: The deed of sale was a forgery, and the transaction was an equitable mortgage, not a sale. He maintained possession of the property.
- Laserna's Defense: He and Diosdado Martirez bought the property from Eliodoro and his siblings in 1946. Martirez later sold his share to Laserna, who then sold the entire property to the Villagracias in 1969. Laserna claimed continuous possession since 1946.
- Villagracias' Defense: They bought the property in good faith from Laserna in 1969 and secured OCT No. 0-995. They also filed forcible entry cases against Eliodoro.
Pre-Trial and Evidence
- The parties admitted the authenticity of the 1969 Deed of Absolute Sale between Laserna and the Villagracias.
- The National Bureau of Investigation (NBI) confirmed the genuineness of Eliodoro's signature and fingerprints on the 1946 Deed of Sale.
- Witnesses testified that Laserna possessed and leased the property, and the Villagracias paid realty taxes.
Issue:
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Ruling:
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Ratio:
Equitable Mortgage vs. Absolute Sale: Under Article 1602 of the Civil Code, a contract may be presumed to be an equitable mortgage if certain circumstances exist, such as inadequate price, continued possession by the vendor, or payment of taxes by the vendor. However, none of these circumstances were present in this case. The 1946 Deed of Sale was a valid and absolute sale, supported by notarization and corroborative evidence.
Burden of Proof: The burden of proof lies with the plaintiff (Eliodoro) to establish his case by preponderance of evidence. Eliodoro failed to provide sufficient evidence to prove his claims, leading to the dismissal of his complaint.
Presumption of Good Faith: Good faith is presumed in favor of buyers unless proven otherwise. The Villagracias acted in good faith when they purchased the property from Laserna, and Eliodoro failed to present evidence to the contrary.
Notarized Documents: Notarized documents, such as the 1946 Deed of Sale, carry evidentiary weight and are presumed valid unless proven otherwise. Eliodoro's self-serving claims were insufficient to overcome this presumption.