Case Digest (G.R. No. L-8012)
Facts:
The case involves Maria Barbosa, who was substituted by her heirs, Elena Maniago and others, as plaintiffs against Francisco S. Mallari and Asuncion Agustin, the defendants. The dispute centers around a homestead land measuring approximately 149,259 square meters, originally patented to Claudio Maniago, Maria Barbosa's late husband, under Homestead Patent No. 16333, registered as Original Certificate of Title No. 294 in Nueva Vizcaya on July 5, 1931. Following Claudio's death, the title was transferred to Maria Barbosa, who received Transfer Certificate of Title No. 649 on February 31, 1935. On November 2, 1937, Maria sold the homestead land to Asuncion Agustin for P2,000, with Francisco Mallari acknowledging a debt of P285 to Maria as part of the sale agreement. Mallari also promised to assist Maria in acquiring another parcel of land and assumed her mortgage obligation with the Philippine National Bank amounting to P600.
However, Maria did not purchase the promis...
Case Digest (G.R. No. L-8012)
Facts:
- Property in Litigation: The subject property is a homestead land with an area of 149,259 square meters, originally patented in the name of Claudio Maniago, Maria Barbosa's late husband, under Homestead Patent No. 16333. It was registered under Original Certificate of Title No. 294 on July 5, 1931. After Claudio's death, the title was transferred to Maria Barbosa, and Transfer Certificate of Title No. 649 was issued in her name on February 31, 1935.
- Sale of the Property: On November 2, 1937, Maria Barbosa executed a deed of sale (Exhibit 1) in favor of Asuncion Agustin, wife of Francisco S. Mallari, for P2,000. On the same day, Francisco Mallari executed an agreement (Exhibit 2) acknowledging a debt of P285 to Maria Barbosa, promising to pay it in November 1937 and to help her acquire a 20-hectare parcel of land near Santiago and Cordon, Isabela.
- Mortgage Assumption: Francisco Mallari also assumed Maria Barbosa's P600 mortgage debt with the Philippine National Bank (Exhibit 4-A).
- Failure to Fulfill Obligations: Maria Barbosa did not acquire the 20-hectare land as promised. On April 22, 1941, she filed a complaint alleging fraud, deceit, and failure to comply with the agreement. She sought annulment of the sale, restoration of ownership, and damages.
- Trial Court Decision: The trial court dismissed the complaint, finding that the sale was valid and that Maria Barbosa had received the agreed consideration. Maria Barbosa died, and her heirs appealed.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Validity of the Sale: The sale was valid as Maria Barbosa received the agreed consideration, and there was no evidence of fraud or deceit.
- Separate Agreement: The obligation to help Maria Barbosa acquire land was a separate agreement and not a condition of the sale. Its non-fulfillment did not affect the validity of the sale.
- Statute of Limitations: The amended complaint introduced a new cause of action for repurchase, which was barred by the statute of limitations. The 5-year period for repurchase under Section 119 of Commonwealth Act No. 141 had expired by the time the amended complaint was filed.
- Relation Back Doctrine: The amendment did not relate back to the original complaint because it introduced a new cause of action rather than amplifying or supplementing the original claims.