Case Digest (G.R. No. 236140) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves a property dispute between petitioner Josefina C. Billote and respondents spouses Victor and Remedios T. Badar, along with Adelaida C. Dalope and Imelda C. Solis. The property in question is a parcel in Urdaneta City, Pangasinan, originally acquired by the spouses Hilario Solis and Dorotea Corla Solis. Hilario died in 1955, after which Dorotea remarried Segundo Billote and had children including Josefina. On July 28, 2001, Dorotea sold an undivided half portion of the land to Josefina for P20,000. Josefina entrusted the papers to her brother William to register the sale but no registration happened. Subsequently, Dorotea, Adelaida, and Imelda executed an extrajudicial settlement in 2002 whereby Dorotea quitclaimed her rights to Adelaida and Imelda, who later secured a reconstituted title (TCT No. 269811) based on a lost owner's duplicate, allowing them to register the property in their names. They sold the entire property to spouses Badar in 2003, who took pos... Case Digest (G.R. No. 236140) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties and Property
- The property at issue is a parcel of land in Urdaneta City, Pangasinan, consisting of 6,894 square meters, originally registered under Transfer Certificate of Title (TCT) No. 15296 in the names of spouses Hilario Solis and Dorotea Corla Solis.
- Hilario and Dorotea acquired the property during their marriage. Hilario died on November 15, 1955, and Dorotea later remarried Segundo Billote.
- Dorotea and Segundo had two children: Josefina C. Billote (petitioner) and William Billote.
- Transactions Affecting the Property
- On July 28, 2001, Dorotea executed a Deed of Absolute Sale conveying an alleged one-half (1/2) portion at the southwestern part (3,447 square meters) of the property to Josefina for P20,000.00.
- Josefina entrusted the original owner’s duplicate copy of TCT No. 15296 and the Deed of Sale to her brother William for registration, but no registration was accomplished due to William's busy schedule.
- On July 13, 2002, Dorotea, with her daughters Imelda Solis and Adelaida Dalope, executed a Deed of Extrajudicial Settlement of Estate of Deceased Person with Quitclaim where Dorotea renounced all interest over the property in favor of her daughters, who then sought to register the instrument.
- Reconstitution of TCT and Subsequent Sales
- Imelda filed a petition to have a second owner's duplicate copy of TCT No. 15296 issued due to alleged loss of the original, granted by Branch 47 RTC on February 24, 2003.
- Using this duplicate, the Deed of Extrajudicial Settlement was registered, resulting in cancellation of TCT No. 15296 and issuance of TCT No. 269811 in the names of Imelda and Adelaida.
- On November 5, 2003, Imelda and Adelaida sold the property covered by TCT No. 269811 to spouses Victor and Remedios Badar (respondents). A new TCT No. 274696 was issued in the Badars’ names.
- Legal Proceedings
- Josefina filed a complaint before RTC for declaration of nullity of titles, recovery of possession and damages against the respondents.
- RTC, in its January 27, 2015 Decision, ruled in favor of the legality of the 2001 Deed of Sale to Josefina for the undivided 1/2 share but recognized the validity of the 2002 Quitclaim and sale by Imelda and Adelaida to spouses Badar for the other half.
- The RTC declared spouses Badar as lawful owners; however, it awarded Josefina damages against Imelda and Adelaida.
- The CA, in its August 2, 2017 Decision, upheld most of the RTC's ruling but increased damages payable by Imelda and Adelaida to Josefina.
- The CA denied Josefina’s Motion for Reconsideration.
- Issues Arising from the Titles
- The CA and Supreme Court declared the February 24, 2003 RTC Decision authorizing the issuance of the second owner’s duplicate of TCT No. 15296 and the second owner's duplicate itself as null and void.
- Consequently, TCT No. 269811 issued in the names of Imelda and Adelaida and the subsequent TCT No. 274696 issued in the names of spouses Badar are also void.
Issues:
- Whether spouses Victor and Remedios Badar are buyers in good faith and for value despite the annotation of Section 4, Rule 74 on the certificate of title.
- Whether the annotation of Section 4, Rule 74 of the Rules of Court on the TCT affects the good faith or validity of the respondent spouses Badar’s acquisition of the subject property.
- The effect of the nullity of the second owner’s duplicate certificate of title and the derived TCTs on ownership and the rights of the parties.
- Validity of the July 2001 sale by Dorotea to Josefina involving the undivided half portion of the property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)