Title
Aron vs. Realon
Case
G.R. No. 159156
Decision Date
Jan 31, 2005
Heirs of Roman Realon sought reconveyance of land from Aron, alleging fraud. SC ruled in Aron's favor due to failure to include indispensable parties and lack of proof of actual fraud.
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Case Digest (G.R. No. 159156)

Facts:

Ownership and Inheritance:
Roman Realon was the owner of two parcels of land: Lot No. 1253 (146,948 sqm) and Lot No. 602 (3,105 sqm) in Carmona, Cavite. Upon his death in 1946, he was survived by his son Alfredo and the children of his deceased son Buenaventura, namely, Marciano, Joaquino, Florentino, Felipe, Marcelo, Sesinando, and Montano.

Extrajudicial Settlement:
On May 14, 1979, Alfredo and his nephews executed an Extrajudicial Settlement, dividing the properties. Lot No. 602 was adjudicated to Alfredo, while Lot No. 1253 was divided: 84,632 sqm to Alfredo and 62,316 sqm to Marciano and his brothers.

Contracts to Sell:
On July 31, 1979, Marciano, acting on behalf of his brothers, executed a Contract to Sell Lot No. 1253 to Ramon P. Aron (petitioner) for ₱186,948. Alfredo also executed a Contract to Sell his share of Lot No. 1253 to Aron for ₱253,196. Both contracts required full payment before the execution of a final deed of sale.

Registration of Property:
The vendors failed to register the property under the Torrens System. On November 11, 1983, Aron filed an application for registration, claiming ownership based on the Contracts to Sell. The RTC granted the application, and OCT No. O-2348 was issued in Aron’s name on September 9, 1993.

Consignation Case:
In August 1994, Aron filed a complaint for consignation, depositing the balance of ₱42,849.23 with the court. The RTC ruled in his favor, declaring the consignation valid and releasing him from his obligations.

Complaint for Reconveyance:
On March 18, 1996, the heirs of Roman Realon (respondents) filed a complaint for reconveyance, alleging that Aron fraudulently obtained the title to the property. The RTC and Court of Appeals ruled in favor of the respondents, ordering the cancellation of OCT No. O-2348 and the reconveyance of the property to the heirs.

Issue:

  1. Whether the respondents were entitled to reconveyance of the property based on alleged fraud by Aron.
  2. Whether the respondents were only required to reimburse Aron ₱310,794.27.
  3. Whether the award of attorney’s fees to the respondents was proper.

Ruling:

The Supreme Court granted the petition. The Court held that the respondents’ complaint was defective because they failed to include all indispensable parties, such as the surviving heirs and signatories to the contracts. The absence of these parties rendered the trial court’s judgment null and void. Additionally, the Court found that the respondents failed to prove actual or extrinsic fraud, which is required to nullify a decree of registration.

Ratio:

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