Case Digest (G.R. No. 190901) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amada Cotoner-Zacarias vs. Spouses Alfredo and Paz Revilla (G.R. No. 190901, November 12, 2014), the petition arises from the annulment of fictitious land transfers over a 15,000-sqm unregistered parcel in Silang, Cavite. Respondents Alfredo and Paz Revilla, fee-simple owners under Tax Declaration No. 7971, borrowed money in 1983 from petitioner Amada Cotoner-Zacarias and agreed verbally to an antichresis arrangement: Amada would occupy and cultivate the land, applying its fruits to interest, principal and taxes, then reconvey upon full payment. Unbeknownst to the spouses, Amada presented in 1979 a forged Kasulatan ng Bilihan ng Lupa to the Provincial Assessor, cancelled the Revillas’ declaration, and secured Tax Declaration No. 19773 in her name. She sold the property to the Casorla spouses in 1984 and they sold it to the Sun spouses in 1991, each obtaining new tax declarations. Alfredo Revilla returned in December 1994, discovered the transfers and the forged signatures in Case Digest (G.R. No. 190901) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Alfredo Revilla and Paz Castillo-Revilla (the Revilla spouses) own an unregistered 15,000-sqm parcel in Silang, Cavite (Tax Dec. No. 7971).
- In 1983, facing financial need for Alfredo’s Saudi Arabia deployment, Paz borrows from Amada Cotoner-Zacarias under an oral antichresis agreement: Amada takes possession, cultivates the land, applies the fruits to interest and principal, and returns the land upon full repayment.
- Undisclosed Forgery and Subsequent Transfers
- Amada presents a fictitious “Kasulatan ng Bilihan ng Lupa” dated March 19, 1979, forging the Revillas’ signatures; Tax Dec. No. 7971 is cancelled and Tax Dec. No. 19773 is issued in Amada’s name.
- August 25, 1984: Amada sells to spouses Adolfo and Elvira Casorla (Tax Dec. No. 30411-A).
- December 16, 1991: Casorla spouses sell to spouses Rodolfo and Yolanda Sun (Tax Dec. Nos. 30852-A, 18584).
- Discovery and Judicial Proceedings
- December 1994: Revillas discover the transfers; February 1995: they learn of the forged deed in a land registration case and demand cancellation and reconveyance, but Amada ignores them.
- November 17, 1995: Revillas file suit (RTC Tagaytay, Civil Case No. TG-1543) for annulment of sales and reconveyance, plus damages, against Amada, the Casorlas, the Suns, and the Provincial Assessor.
- RTC Decision (Aug. 3, 2006): Declares all transfers from Dec. No. 7971 to No. 18584 null and void; reinstates Revillas’ title and possession; awards P50,000 moral, P20,000 exemplary, P80,000 attorney’s fees to Revillas; P467,350 actual, P50,000 moral, P20,000 exemplary, P100,000 attorney’s fees to Suns.
- CA Decision (Aug. 13, 2009): Dismisses Amada’s appeal; partially grants Suns’ appeal on interest: 6% p.a. on P467,350 from Feb. 3, 1995 to finality; 12% p.a. thereafter.
- SC Petition: Amada challenges prescription/laches, antichresis writing requirement (Art. 2134 CC), burden of proof, docket fees (P50,000 vs. alleged P12 million), conjugal consent, and Suns’ good faith.
Issues:
- Is the Revilla spouses’ cause of action barred by prescription or laches?
- Did the trial court acquire jurisdiction despite docket fees based on P50,000 instead of the property’s alleged P12 million value?
- Did the Court of Appeals err in upholding reinstatement and reconveyance to the Revilla spouses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)