Title
Alfiler vs. Spouses Cayabyab
Case
G.R. No. 217111
Decision Date
Mar 13, 2023
A void Deed of Absolute Sale, executed post-death of the principal without valid authority, invalidated respondents' claim, leading to dismissal of the ejectment case.
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Case Digest (G.R. No. 217111)

Facts:

Background of the Property

The case involves a parcel of land located at 186 Pajo Street, Barangay Quirino 2-C, Quezon City, with an area of 266.9 square meters (subject property). The property is registered under Transfer Certificate of Title No. RT-115646 (324155) in the name of Quintin Santiago, Jr., married to Violeta E. Santiago.

Amicable Settlement (1985)

In March 1985, Quintin filed a complaint for ejectment and squatting against Lilah Gail Corpuz Alfiler's (petitioner) mother, Linglingay Corpuz, and others. On May 1, 1985, the parties entered into an Amicable Settlement, wherein Linglingay, et al. agreed to purchase the property for P146,000.00, payable in installments. However, only P72,425.00 was paid, with the last payment made in June 1986.

Death of Quintin and Subsequent Sale

Quintin died on March 12, 1997. On August 20, 1997, a Deed of Absolute Sale (DOAS) was executed by Norman Santiago, Quintin's alleged attorney-in-fact, in favor of spouses John and Geraldine Cayabyab (respondents). Respondents claimed ownership of the property based on this DOAS.

Ejectment Case (2010)

On March 18, 2010, respondents filed a Complaint for Ejectment against petitioner and others, alleging illegal possession of the property since 1997. Petitioner and her co-defendants argued that the DOAS was void because Quintin had already died before its execution, and no valid Special Power of Attorney (SPA) authorized Norman to sell the property.

Lower Court Rulings

  • MeTC Decision (2011): Ruled in favor of respondents, ordering petitioner and others to vacate the property and pay damages.
  • RTC Decision (2013): Affirmed the MeTC Decision, stating that petitioner failed to prove a better right of possession.
  • CA Resolution (2013 & 2015): Dismissed petitioner's Petition for Certiorari, ruling that it was the wrong mode of appeal.

Issue:

  1. Whether the Court of Appeals erred in dismissing petitioner's Petition for Certiorari on the ground of being the wrong mode of appeal.
  2. Whether the Deed of Absolute Sale (DOAS) executed by Norman Santiago is valid, given that Quintin had already died before its execution and no valid SPA was presented.

Ruling:

The Supreme Court granted the petition and reversed the CA Resolutions. The Court held that:

  1. The DOAS is void ab initio because Quintin had already died before its execution, and no valid SPA was presented to authorize Norman to sell the property.
  2. Respondents failed to establish their right of possession over the property, as the DOAS was invalid.
  3. The MeTC complaint for ejectment should be dismissed for lack of factual and legal basis.

Ratio:

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