Case Digest (G.R. No. 175483)
Facts:
In Valentina S. Clemente v. Court of Appeals, G.R. No. 175483, decided on October 14, 2015 under the 1987 Constitution, the petitioner, Valentina S. Clemente, is the granddaughter of the late Adela de Guzman Shotwell, who owned three adjoining lots (Nos. 32, 34, 35-B) in Scout Ojeda Street, Diliman, Quezon City. In 1985 and 1987, Adela “simulated” transfers of Lots 32 and 34 to her grandsons, Carlos Jr. and Dennis, who reconveyed the properties back to her in 1989 at her request. On April 25, 1989, Adela executed two Deeds of Absolute Sale ostensibly conveying all three lots and improvements to petitioner for a total of ₱310,000.00, and on the same day granted her a Special Power of Attorney to manage these and other assets. Both instruments were notarized in Quezon City, registered later in 1989 and 1990, and titles were issued in petitioner’s name. Adela died in the United States on January 14, 1990. Thereafter, petitioner sought to eject her aunts and uncle (Annie S. JalandooCase Digest (G.R. No. 175483)
Facts:
- Case Background
- Petitioner Valentina S. Clemente filed a Rule 45 petition for review on certiorari against the Court of Appeals (CA) Decision of August 23, 2005 and Resolution of November 15, 2006 in CA-G.R. CV No. 70918.
- She challenged the CA’s affirmance of the RTC’s nullification of two deeds of absolute sale executed by her grandmother, Adela de Guzman Shotwell, over three adjoining lots in Quezon City.
- Property and Transactions
- Adela owned Lots 32, 34, and 35-B on Scout Ojeda Street, Diliman, Quezon City, including her “big house.”
- In 1985 and 1987, Adela simulated transfers of Lots 32 and 34 to grandsons Carlos V. Shotwell, Jr. and Dennis V. Shotwell; reconveyances were signed April 18, 1989.
- On April 25, 1989, Adela executed:
- A deed of absolute sale of Lots 32 and 34 for ₱250,000 to petitioner;
- A deed of absolute sale of Lot 35-B for ₱60,000 to petitioner;
- A special power of attorney (SPA) appointing petitioner administratrix of all her Philippine properties.
- Petitioner registered Titles Nos. 19811 (Lot 32) and 19809 (Lot 34) on September 25, 1989; Adela died January 14, 1990 in the United States.
- Respondents (Adela’s children Annie, Carlos Sr., Anselmo) later filed Civil Case No. Q-90-6035 for reconveyance, amending to include Lot 35-B upon discovery of its deed.
- RTC Decision (Feb. 26, 2001) declared the deeds void, canceled Titles Nos. 19809, 19811, and 26558, and ordered reconveyance. CA affirmed as simulated and lacking consideration; petition for reconsideration denied.
Issues:
- Whether the CA erred in affirming the RTC that the deeds of absolute sale are simulated, lack consideration, and are therefore void and inexistent.
- Whether any implied or resulting trust arises from the transactions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)