Case Digest (G.R. No. 174826) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dioscoro Poliao Bacala v. Heirs of Spouses Juan Poliao and Corazon Rom, petitioner Dioscoro Poliao Bacala, as substitute judicial guardian of the mentally incapacitated Aquilino O. Poliao, challenged the validity of a Deed of Sale and related Agreement executed on April 13, 1992 by his uncle, Anecito Poliao, and respondent Juan R. Poliao. Anecito and his wife Clara owned an 80,003-square-meter coconut land in Cocomon, Lupon, Davao Oriental (TCT No. T-3353), which Anecito allegedly sold to Juan for ₱15,000. After Anecito’s intestate death in 1994, Juan purportedly executed a Deed of Voluntary Transfer in 1996 conveying the same property to his children. Meanwhile, Aproniana Poliao Balisalisa secured letters of guardianship over Aquilino and his brother Ducepino in 1996; Ducepino died during trial. On September 3, 1996, Aproniana (later substituted by Dioscoro) filed Civil Case No. 1863 before the RTC of Lupon for nullity of sale and agreement, accounting, damages and injunctiv Case Digest (G.R. No. 174826) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Petitioner: Dioscoro Poliao Bacala, substituted judicial guardian of mentally incompetent heir Aquilino O. Poliao.
- Respondents: Heirs of spouses Juan Poliao and Corazon Rom—Ruben R., Brendo R., Carlito R., and Bandy R. Poliao—represented by Ruben R. Poliao.
- Transactions Contested
- Anecito and Clara Poliao, parents of Aquilino and Ducepino (both incapacitated), owned an 80,003 sqm coconut land in Cocomon, Lupon, Davao Oriental (TCT No. T-3353).
- On April 13, 1992, Anecito purportedly sold the land to his brother Juan for ₱15,000.00 and concurrently executed an Agreement: (a) Anecito to enjoy usufruct during his lifetime; (b) Juan to support Aquilino and Ducepino after Anecito’s death; (c) breach renders the sale nugatory.
- While guardianship over the incapacitated heirs was pending (Special Proc. No. 237, RTC Mati), Juan executed (Feb. 23, 1996) a Deed of Voluntary Transfer of the property to his children.
- Procedural History
- Aproniana PoliAo Balisalisa (Judicial Guardian) filed, on Sept. 3, 1996, Civil Case No. 1863 RTC Lupon: complaint for nullity/annulment of sale and agreement, accounting, damages, fees, and injunctive relief.
- RTC (Feb. 18, 2002) voided the 1992 Deed of Sale, Agreement, and 1996 Transfer for lack of consideration, simulation, and non-compliance with donation formalities; ordered reconveyance, accounting of harvests, and damages.
- CA (Mar. 10, 2011 Decision; Feb. 3, 2012 Resolution) reversed and set aside the RTC decision, upholding the validity of the Deed of Sale, Agreement, and Transfer under presumption of consideration and best evidence rule.
- Bacala’s Petition for Review on Certiorari (G.R. No. 200608) assails the CA rulings.
Issues:
- Does gross inadequacy of the price stated in the Deed of Sale invalidate the contract of sale?
- What is the true nature of the transaction between Anecito and Juan—sale subject to resolutory condition or donation mortis causa?
- Are the Deed of Sale, Agreement, and Deed of Voluntary Transfer valid under the rules on contracts, evidence, and rescission?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)