Case Digest (G.R. No. 230599)
Facts:
Alfredo Sulit, Julita Sulit, and the Heirs of Arsenio Sulit, represented by Alfredo Sulit, Petitioners, v. Spouses Eugenio and Zenaida Alfonso, Spouses Efren and Eugenia Sulit, Spouses Reynaldo and Norma Dizon, Spouses Manalili, Leonilo Danilo Disor, Eiselle S. Alfonso, Elita S. Alfonso, Edwin S. Alfonso, Crisanta Magtalas and the Register of Deeds of Bulacan, Respondents, G.R. No. 230599, January 20, 2021, Supreme Court Third Division, Inting, J., writing for the Court.The dispute concerns a 4,086-sq.m. parcel in Inaon, Pulilan, Bulacan (the subject property) originally titled to Spouses Arsenio and Julita Sulit. On October 15, 1979 the Spouses Sulit executed a Deed of Absolute Sale conveying the property to two of their children, Efren Sulit and Zenaida Alfonso, and Transfer Certificate of Title (TCT) No. T-257536 issued in their names. On December 6, 1979 a counter Deed of Sale reconveyed the property to the parents. Despite this, Efren and Zenaida caused subdivision and sold portions to various third parties, including Spouses Reynaldo and Norma Dizon, Spouses Manolito and Juliana Esguerra, Spouses Guillermo and Erlinda Manalili, Crisanta Magtalas, Leonilo Danilo Disor, and several children of the Alfonsos (Eiselle, Elita, Edwin), with subsequent TCTs registered in their favor.
On July 7, 2005 petitioners (the heirs and Julita) filed a Complaint for Annulment of Sale and/or Declaration of Nullity of Title, Reconveyance and Damages with prayer for injunctive relief in the Regional Trial Court (RTC), Branch 11, Malolos City, Bulacan (Civil Case No. 486-M-2005), impleading the private purchasers and the Register of Deeds. Petitioners alleged that the initial sale was an accommodation (an implied trust), that the Spouses Efren and Zenaida had no authority to convey, and that the counter Deed of Sale evidenced the parents’ continuing ownership. Private respondents counterclaimed that the transactions evidenced donation or valid sale and that subsequent purchasers acquired title in good faith and for value. Respondents also relied on an earlier case: Branch 8, RTC, Malolos City dismissed a complaint filed by Efren and Zenaida against their parents (Civil Case No. 948-M-99) and the Court of Appeals (CA) affirmed on April 30, 2004 (CA-G.R. CV No. 77496), declaring both the October 15, 1979 and December 6, 1979 Deeds of Sale void for lack of consideration.
The RTC denied petitioners’ motion for summary judgment (June 5, 2007) and, after trial, rendered a Decision dated May 19, 2014 dismissing the complaint for lack of merit principally on prescription grounds, and noting that purchasers of Torrens-registered land are ordinarily protected absent proof of bad faith. The RTC denied reconsideration (July 21, 2014). Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 103462). In its Decision dated December 28, 2016 the CA affirmed dismissal of the complaint but disagreed with the RTC on prescription: the CA held the action for reconveyance was imprescriptible in view of the prior RTC/CA rulings declaring the deeds void, yet nonetheless barred petitioners from recovering the lots because the private respondents were innocent purchasers for value protected by the Torrens system; the CA suggested petitioners could still pursue ...(Subscriber-Only)
Issues:
- Procedural: Should the petition for review be dismissed for defective verification and certification against forum shopping because Alfredo signed without showing authorization from his co-petitioners?
- Substantive: Were the private respondents innocent purchasers for value and in good faith entitled to protection under the Torrens system, thereby precluding reconveyance and cancellation of their TCTs?
- Substantive: Were petitioners entitled to an award of damages against the private respondents or against Spouses Efren and Zenaida Alfons...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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