Title
Contreras vs. Court of Appeals
Case
G.R. No. 164819
Decision Date
Mar 9, 2007
A dispute over ownership of a house and land arises when the Alcantaras claim ownership of the house and the Contreras claim ownership of the land, leading to a court decision in favor of the Alcantaras based on their right of pre-emption and redemption under Article 1622 of the Civil Code.
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Case Digest (G.R. No. 164819)

Facts:

  • The case involves a dispute over the ownership of a house and land on San Jose Street, Antipolo, Rizal.
  • Petitioner: Jerty Pascual Contreras (deceased), represented by her mother, Lourdes Pascual.
  • Respondents: Spouses Danilo and Isabelita Alcantara.
  • The house was originally owned by Eulalia Leis and built on land owned by Filomena Gatchalian.
  • The house was mortgaged and acquired by the Rural Bank of Teresa (Rizal), Inc. (RBTRI) due to non-payment.
  • In 1980, Isabelita Bumatay (later Alcantara) repurchased the house from RBTRI.
  • The land changed ownership multiple times and was mortgaged to Capitol City Development Bank (CCDB) by Felipe Matawaran and Ofelia Oliveros.
  • CCDB acquired the land after foreclosure in 1984.
  • In 1990, CCDB sold the land to Contreras, who had been renting the lower floors of the house from the Alcantaras since 1987.
  • The Alcantaras claimed ownership of the house and an adjacent lot, seeking to annul the Deed of Absolute Sale between CCDB and Contreras, citing their right of pre-emption and redemption under Article 1622 of the Civil Code.
  • The Regional Trial Court (RTC) of Antipolo ruled in favor of the Alcantaras, nullifying the sale to Contreras and allowing the Alcantaras to exercise their right of pre-emption.
  • The Court of Appeals upheld the RTC's decision, leading to the present petition before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the decision of the Court of Appeals was valid despite the absence of signatures on the copy received by the petitioner, as the official records contained the necessary signatures.
  2. The Supreme Court found that the RTC did not exceed its jurisdiction and that t...(Unlock)

Ratio:

  1. The Supreme Court noted that the unsigned copy of the Court of Appeals decision received by the petitioner was a clerical error and did not affect the validity of the decision. The official records of the Court of Appeals contained the signatures of the ponente and concurring justices, fulfilling the requirements of Section 1, Rule 36 of the Rules of Civil Procedure. The Court emphasized that the purpose of the signature requirement is to provide indubitable proof that the judges who prepared and concurred in the decision actually did so. Since the official records were properly signed, the decision was valid.
  2. Regarding the second issue, the Supreme Court explained that the RTC's...continue reading

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