Case Digest (G.R. No. 32380)
Facts:
In Damaso T. Ambray and Ceferino T. Ambray, Jr. v. Sylvia A. Tsourous, et al. (G.R. No. 209264, July 5, 2016), petitioners Damaso T. Ambray and Ceferino T. Ambray, Jr. claimed ownership of Lot 2-C of subdivision plan Psd-04-009554, covered by Transfer Certificate of Title No. T-41382 in San Pablo City, Laguna. They relied on a notarized Deed of Absolute Sale dated January 16, 1978, by which their parents, Ceferino Ambray, Sr. and Estela Trias, purportedly sold “a portion of Lot 2 of Pcs-12441” for ₱150,000.00; however, registration was delayed until February 5, 1996. In June 1996 the respondents—nine siblings of the deceased Ceferino, Sr. and Estela—discovered that TCT No. T-41382 was issued in favor of the petitioners. They first filed a falsification case (Criminal Case No. 39153) in the Municipal Trial Court in Cities, where petitioners were acquitted on October 30, 2000 for lack of proof. Thereafter, respondents instituted Civil Case No. SP-5831(01) for annulment of title, rCase Digest (G.R. No. 32380)
Facts:
- Parties and Property
- Petitioners: Damaso T. Ambray and Ceferino T. Ambray, Jr., registered owners of Lot 2-C of Psd-04-009554, covered by TCT No. T-41382.
- Respondents: Sylvia A. Tsourous (deceased) and eight Ambray siblings, heirs of Ceferino Ambray, Sr. (d. 1987) and Estela Trias (d. 2002), claiming interest in the original Lot 2 of Pcs-12441 (4,147 sqm), formerly under TCT No. T-11259.
- Land Transactions
- December 28, 1977: Ceferino Sr. mortgaged Lot 2 for ₱180,000; mortgage discharged September 16, 1984.
- January 16, 1978: Notarized Deed of Absolute Sale conveying “a portion of Lot 2” to petitioners for ₱150,000—registered only on February 5, 1996.
- August 1984: Lot 2 subdivided into Lots 2-A, 2-B, and 2-C; TCT No. T-22749 issued in Ceferino Sr.’s name, later canceled upon issuance of TCT No. T-41382 in petitioners’ names.
- Pre-trial Proceedings
- June 1996: Respondents discovered TCT T-41382; filed criminal falsification case (MTCC No. 39153); petitioners acquitted October 30, 2000 for failure to prove guilt.
- 2001: Respondents filed Civil Case No. SP-5831 for annulment of title, reconveyance, and damages. RTC dismissed on res judicata (2002); CA reversed (2005) and remanded.
- Trial Court and Appellate Rulings
- June 11, 2010 RTC Decision: Deed of Sale and TCT T-41382 nullified as spurious; ordered reconveyance to heirs and issuance of new title; found signatures forged and sale impossible pre-subdivision.
- April 25, 2013 CA Decision: Affirmed RTC; denied moral/exemplary damages and attorney’s fees for lack of factual/ legal basis. Reconsideration denied September 24, 2013.
- Supreme Court Petition
- Petitioners and respondents filed Rule 45 petition for review on certiorari.
- Sole issue: validity of the January 16, 1978 Deed of Sale and TCT T-41382 covering Lot 2-C.
Issues:
- Did the Court of Appeals err in affirming the nullification of the Deed of Absolute Sale of January 16, 1978 and Transfer Certificate of Title No. T-41382 covering Lot 2-C in petitioners’ names?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)