Facts:

The case involves the petitioners Avelino Banaag, Rosabel B. Banaag, and Rowena B. Banaag, and the respondents Manuel S. Bartolome, Estanislao S. Bartolome, Expedita S. Bartolome, Peter S. Bartolome, and the Intermediate Appellate Court. The petition was brought before the Supreme Court on October 28, 1986, to review a decision made by the Intermediate Appellate Court on October 13, 1986, which upheld a previous ruling from the Court of First Instance of Laguna and San Pablo City dated August 30, 1979. This ruling declared null and void a deed of sale executed on December 31, 1949, of two parcels of land from spouses Ildefonso Bartolome and Adelaida Jaro to their daughter, Rosaura Bartolome.

The couple had two children, Rosaura and Guillermo Bartolome, the latter dying at a young age. They initially acquired two properties from Maria Ambray for P500.00 in 1946, before transferring these properties to their daughter for a mere P1.00. Rosaura eventually became the guardian of her

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Facts:

Acquisition and Registration of the Properties

• Ildefonso Bartolome and Adelaida Jaro, husband and wife, acquired two parcels of land (Lot No. 5 and Lot No. 10) in San Pablo City for the sum of P500.00 from Maria Ambray.
• The properties were registered in their names under Original Certificate of Title No. 0-12, with specific descriptions and areas as indicated in the title.

Subsequent Deed of Absolute Sale to Their Daughter

• On December 31, 1949, the spouses sold the two parcels to their daughter, Rosaura Bartolome, for the highly inadequate price of P1.00.
• Following this sale, Rosaura was issued Transfer Certificate of Title (TCT) No. T-582 covering the properties described in the original title.

Guardianship Proceedings and Property Inventory

• A guardianship proceeding was instituted for the incompetent Adelaida Jaro in the Court of First Instance of Laguna and San Pablo City, where Rosaura was appointed guardian of both the person and property of Adelaida.
• The inventory of Adelaida’s estate included Lot No. 5 and Lot No. 10.
• Acting in her capacity as guardian, Rosaura requested and received authority from the court to sell a portion of the property to finance the construction of a house.
• On August 31, 1951, Rosaura transferred part of Lot No. 5 (designated as Lot No. 5-B) and Lot No. 10 to the Young Man’s Christian Association (YMCA), leading to the issuance of a new title (TCT No. 663) for the remaining property.

Family Developments and Subsequent Litigation

• Rosaura later married Avelino Banaag and bore two children, Rosabel and Rowena Banaag.
• Upon Rosaura’s death on June 14, 1961, Ildefonso Bartolome assumed guardianship of incompetent Adelaida Jaro.
• In Civil Case No. SP-642, Rosabel and Rowena, represented by Avelino Banaag, sought to clear the title affected by the transfer (TCT No. T-663) through a compromise agreement that addressed issues of joint ownership and usufruct rights, and set forth arrangements regarding the disposition of the property and its improvements.

The Extra-marital Relationship and Birth of Additional Claimants

• Beginning in June 1949, while still married, Ildefonso Bartolome maintained an extra-marital relationship with Constancia Santiago, a widow, resulting in the birth of four children: Manuel (b. May 10, 1951), Estanislao (b. September 28, 1952), Minerva Expedita (b. April 19, 1956), and Peter (b. June 29, 1966).
• After Adelaida Jaro’s death on January 8, 1968, Constancia Santiago and her children began residing in a house constructed on the property covered by the title issued in favor of Rosabel and Rowena.

Filing of the Petition for Review and the Lower Courts’ Decisions

• On April 28, 1973, Constancia Santiago and her children initiated a complaint to annul the earlier deed of absolute sale executed between Ildefonso Bartolome, Adelaida Jaro, and Rosaura Bartolome.
• Trial proceedings were held, and on August 30, 1979, the Court of First Instance declared the deed of absolute sale null and void for being simulated, based on the gross inadequacy (fictitious price) and manifest incongruity between the acquisition price (P500.00) and the sale price (P1.00).
• The judgment also ordered the cancellation of TCT No. T-6215 (issued later in place of TCT No. T-663) and provided for the re-issuance of a title subdividing the property interests between the parties.
• Petitioners (the Banaag family) appealed the decision to the Intermediate Appellate Court, contesting several findings including:
• The nullification of the deed of sale.
• The classification of the house as conjugal property.
• The procedural issue regarding dismissal of the complaint based on the capacity of the minor respondents.
• The Intermediate Appellate Court affirmed the trial court’s decision in its ruling dated October 13, 1986.
• The issues were elevated to the Supreme Court via a petition for review on certiorari under Rule 45.

Submission of Briefs, Assignment of Errors, and Final Determination

• Petitioners raised multiple assigned errors, including:
• Alleged improper reliance on a decision in Civil Case No. SP-642 which did not include the private respondents as parties.
• Erroneous nullification of the deed of sale and improper declaration regarding the property’s conjugal status.
• Contentions regarding the recognition of private respondents as acknowledged spurious children without their formal request.
• The Supreme Court, emphasizing that rights adjudicated by competent courts remain conclusive on the parties involved, found no reversible error in the rulings of both the trial and appellate courts.
• The Supreme Court validated the nullity of the deed for being simulated, upheld the determination regarding the conjugal nature of the house, and confirmed the evidentiary basis for recognizing the private respondents as the acknowledged spurious children of Ildefonso Bartolome.

Issue:

• Whether the trial court correctly nullified the deed of absolute sale on the ground that it was simulated, given the gross inadequacy (fictitious price) involved.
• Whether the declaration that the house, constructed on a portion of the subdivided property, is conjugal property—based on the source of the construction funds and the nature of the properties acquired during the marriage—is legally correct.
• Whether the trial court erred in its procedural rulings, including the dismissal of the motion to dismiss the complaint despite the minors being represented and their status as alleged spurious children.
• Whether the evidence presented—including authentic writings and continuous possession—adequately supports the recognition of the private respondents as voluntarily acknowledged spurious children of Ildefonso Bartolome without the need for a separate judicial declaration.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)