Case Digest (G.R. No. 133148)
Facts:
J.R. Blanco, as the Administrator of the Intestate Estate of Mary Ruth C. Elizalde, G.R. No. 133148, November 17, 1999, the Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.Petitioner Blanco sued respondents William H. Quasha, Cirilo F. Asperilla, Jr., Sylvia E. Marcos, Delfin A. Manuel, Jr., Cirilo E. Doronila and Parex Realty Corporation after the death of Mary Ruth C. Elizalde, an American national who owned a house and lot in Forbes Park, Makati. During Elizalde’s lifetime, on May 22, 1975, acting through an attorney‑in‑fact, she executed a Deed of Sale conveying the 2,500 sq.‑m. parcel to Parex Realty Corporation for P625,000, payable in twenty‑five annual installments of P25,000. Simultaneously Parex executed a 25‑year lease back to Elizalde with annual rent of P25,000.08, the rent to be credited against the installment payments. The original title was cancelled and a new Transfer Certificate of Title in Parex’s name was issued on May 27, 1975; Elizalde later executed a Confirmation and Ratification of the sale on October 17, 1975. Despite the transfer of title Elizalde continued to occupy the property and paid subdivision dues and, pursuant to the lease, real estate taxes.
Elizalde died on March 1, 1990. As special administrator, petitioner Blanco demanded reconveyance of the property or assignment of Parex shares to the estate on June 13, 1990; respondents ignored the demand. Petitioner filed suit for reconveyance on July 10, 1990, alleging the sale‑lease‑back was absolutely simulated and fictitious, executed to evade the effects of this Court’s decision in Republic v. Quasha and related to the Parity Amendment and PD 471; petitioner contended Elizalde received no cash consideration.
The Regional Trial Court, Makati, Branch 147, rendered judgment on December 20, 1994 declaring the sale fictitious, declaring the estate the true owner, ordering reconveyance and awarding attorney’s fees. On appeal the Court of Appeals, Fourth Division, reversed and dismissed the reconveyance complaint on February 18, 1998. Petitioner moved for reconsideration and sought inhibition of the CA justices alleging influence peddling; the CA denied the motion on April 1, 199...(Subscriber-Only)
Issues:
- Under Rule 45, may the Supreme Court review the Court of Appeals’ factual findings that the sale‑lease‑back was not simulated?
- Was the sale‑lease‑back between Mary Ruth Elizalde and Parex Realty Corporation simulated and therefore void, entitling the estate to reconveyance?
- Were petitioner’s allegations of influence peddling and the motion to inhibit the Court of Appeals justi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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