Facts:

The case involves J.R. Blanco, the special administrator of the intestate estate of Mary Ruth C. Elizalde, as the petitioner, and William H. Quasha, Cirilo Asperilla, Jr., Sylvia E. Marcos, Delfin A. Manuel, Jr., Cirilo E. Doronila, and Parex Realty Corporation as the respondents. Mary Ruth C. Elizalde, an American national, owned a house and lot located at 515 Buendia Extension, Forbes Park, Makati, covered by Transfer Certificate of Title No. 106110. On May 22, 1975, she, through her attorney-in-fact Don Manuel Elizalde, executed a Deed of Sale transferring the property to Parex Realty Corporation for P625,000, payable in twenty-five annual installments of P25,000. Simultaneously, a Contract of Lease was executed, allowing Elizalde to lease the property back for twenty-five years at a monthly rental of P2,083.34, which would be credited against the purchase price. Despite the sale, Elizalde continued to pay association dues and realty taxes until her death on March 1, 1990....

Facts:

Property Ownership and Sale

Mary Ruth C. Elizalde, an American national, owned a house and lot on a 2,500 square-meter parcel of land at 515 Buendia Extension, Forbes Park, Makati, covered by Transfer Certificate of Title No. 106110. On May 22, 1975, through her attorney-in-fact Don Manuel Elizalde, she entered into a Deed of Sale with Parex Realty Corporation (Parex) for P625,000.00, payable in 25 annual installments of P25,000.00.

Lease Agreement

Simultaneously, Parex executed a Contract of Lease with Mary Ruth Elizalde, leasing the same property back to her for 25 years at a monthly rental of P2,083.34 (P25,000.08 annually). The rental payments were to be credited against the annual installments of the purchase price.

Transfer of Title

Following the sale, TCT No. 106110 was canceled, and TCT No. S-6798 was issued in Parex's name on May 27, 1975. Mary Ruth Elizalde later confirmed and ratified the Deed of Sale on October 17, 1975.

Post-Sale Actions

Despite the transfer of title, Mary Ruth Elizalde continued to pay Forbes Park Association dues and garbage fees until her death in 1990. She also paid realty taxes during the lease term, as stipulated in the lease contract.

Death and Demand for Reconveyance

Mary Ruth Elizalde died on March 1, 1990. On June 13, 1990, J.R. Blanco, the special administrator of her estate, demanded the reconveyance of the property or the assignment of Parex shares to the estate. When respondents ignored the demand, Blanco filed an action for reconveyance on July 10, 1990, alleging that the sale was simulated to circumvent the effects of the Republic v. Quasha ruling, which prohibited Americans from owning private agricultural lands in the Philippines.

Issue:

1. Whether the sale-lease-back agreement between Mary Ruth Elizalde and Parex was simulated and therefore null and void.
2. Whether the estate of Mary Ruth Elizalde is entitled to reconveyance of the property.
3. Whether the Court of Appeals erred in reversing the trial court's decision.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court ruled that the sale-lease-back agreement was valid and binding, and the estate of Mary Ruth Elizalde was not entitled to reconveyance of the property. The petition was dismissed.