Title
Supreme Court
Ang vs. Pacunio
Case
G.R. No. 208928
Decision Date
Jul 8, 2015
A 98,851-sqm land dispute arose when an impostor sold deceased owner Udiaan's property to petitioner Ang. Respondents, claiming inheritance, sued for nullity of sale. SC ruled respondents lacked standing, reinstating RTC's dismissal.

Case Digest (G.R. No. 208928)
Expanded Legal Reasoning Model

Facts:

  • Parties and Subject Matter
    • The petition arose from a Complaint filed on March 19, 2003, for Declaration of Nullity of Sale, Reconveyance, and Damages by respondents Pedrito N. Pacunio, Editha P. Yaba, Severino Pacunio, Teresita P. Torralba, Susana Loberanes, Christopher N. Pacunio, and Pedrito P. Azarcon against petitioner Andy Ang before the Regional Trial Court (RTC) of Cagayan de Oro City.
    • The case involves a 98,851-square meter parcel of land originally registered under Original Certificate of Title (OCT) No. T-3593 in the name of Felicisima Udiaan ("Udiaan") (the "subject land").
    • Respondents claimed to be grandchildren and heirs of Udiaan, who died on December 15, 1972, and asserted their succession rights over the subject land.
  • Circumstances Surrounding the Disputed Sale
    • On July 12, 1993, an impostor allegedly pretending to be Udiaan sold the subject land to petitioner via a Deed of Absolute Sale dated the same day (the "Questioned Deed of Absolute Sale").
    • Transfer Certificate of Title (TCT) No. T-79051 was subsequently issued in petitioner’s name following cancellation of OCT No. T-3593.
    • Petitioner took possession of the land in 1997 and used it for his livestock business. Respondents notified petitioner that he did not validly acquire the land and demanded return thereof, but petitioner refused.
  • Petitioner’s Position
    • Petitioner denied allegations and argued:
      • The seller represented herself as Udiaan and produced identification and original title during sale execution.
      • Initially prevented from entering the land due to occupation by Heirs of Alfredo Gaccion ("Heirs of Gaccion").
      • Subsequently “bought” the subject land anew from the Heirs of Gaccion to secure peaceful possession.
      • He was a buyer in good faith, for value, without knowledge of any defects in title.
      • Respondents were never in possession of the land and never paid property taxes thereon.
    • Claimed to have been duped into buying the land twice.
  • Procedural History
    • After pre-trial, parties filed memoranda supporting their positions for summary judgment.
    • RTC issued Summary Judgment on September 12, 2006, dismissing the case for lack of merit on the basis that respondents failed to prove real party in interest status by establishing their succession rights to Udiaan's estate.
    • Respondents appealed to the Court of Appeals (CA).
  • Court of Appeals’ Decision and Resolution
    • In a Decision dated September 28, 2012, the CA:
      • Affirmed with modification the RTC ruling.
      • Declared the Questioned Deed of Absolute Sale null and void as it was executed by an impostor after Udiaan’s death.
      • Validated the sale between petitioner and Heirs of Gaccion over a 3,502 sq. m. portion of the land.
      • Apportioned the subject land among petitioner (3,502 sq. m.), Heirs of Gaccion (6,398 sq. m.), and Udiaan’s children (remainder).
      • Found respondents not to be real parties in interest due to failure to establish succession rights under right of representation.
    • Petitioner moved for reconsideration, which the CA denied on August 13, 2013.
    • Petitioner filed a petition for review on certiorari before the Supreme Court.

Issues:

  • Whether the Court of Appeals correctly:
    • Declared the nullity of the Questioned Deed of Absolute Sale executed by an impostor.
    • Distributed portions of the subject land to respondents, Heirs of Gaccion, and Udiaan’s children despite ruling that respondents are not real parties in interest to the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.