Case Digest (G.R. No. L-32213)
Facts:
Amada Cotoner-Zacarias v. Spouses Alfredo Revilla and the Heirs of Paz Revilla, G.R. No. 190901, November 12, 2014, Supreme Court Second Division, Leonen, J., writing for the Court. Petitioner Amada Cotoner‑Zacarias sought review of the Regional Trial Court and Court of Appeals decisions that annulled certain transfers of an unregistered parcel of land in Silang, Cavite, and ordered reconveyance to respondents Alfredo Revilla and Paz Castillo‑Revilla; the petition was filed under Rule 45 of the Rules of Court. (Carpio, (Chairperson), Brion, Del Castillo, and Mendoza, JJ., concur.)The Revilla spouses were owners in fee simple of an unregistered 15,000‑square‑meter parcel covered by Tax Declaration No. 7971. In 1983 Paz Revilla borrowed money from petitioner Amada; the parties purportedly agreed that Amada would take possession, cultivate the land, apply the fruits to the loan and taxes, and return the property upon full payment. Unbeknownst to the Revillas, petitioner presented a document titled Kasulatan ng Bilihan ng Lupa dated March 19, 1979, showing the Revillas as sellers and Amada as buyer; Tax Declaration No. 7971 was cancelled and new declarations were issued in Amada’s name and later in the names of subsequent transferees (the Casorla spouses, then the Sun spouses).
Upon Alfredo’s return from Saudi Arabia in December 1994 the Revillas discovered the tax declaration in the Suns’ name. In February 1995 they were served a pleading in the Sun spouses’ land registration case and then examined the Kasulatan, finding their signatures falsified. They demanded cancellation and reconveyance; Amada did not act. On November 17, 1995 the Revilla spouses filed suit in the Regional Trial Court (Branch 18, Tagaytay City) for annulment of sales and transfers, reconveyance, and damages against Amada, the Casorlas, the Suns, and the Provincial Assessor.
The RTC (decision dated August 3, 2006) found the Kasulatan to be fictitious, declared the chain of transfers null and void, reinstated the Revillas’ title/tax declaration and possession, and awarded damages against Amada (including moral, exemplary damages and attorney’s fees) and against the Sun spouses in part. Amada appealed; the Sun spouses partially appealed the damages award. The Court of Appeals (CA-G.R. CV No. 88600, decision dated August 13, 2009) dismissed Amada’s appeal and modified the RTC decision to award interest on certain sums; Amada’s motion for reconsideration was denied, prompting the present Rule 45 petition.
In the Supreme Court petition Amada argued (inter alia) that: the parties’ arrangement was an oral antichresis void under Article 2134 of the Civil Code for lacking a written specification of principal and interest; the Kasulatan and subsequent transfers were valid and supported by testimonial evidence; the Revillas’ claim was barred by laches (they allegedly slept on their rights for over 16 years); the trial court lacked jurisdiction because docket fees should have been calculated on P12,000,000 (a property valuation mentioned at pre‑trial) rather than the P50,000 prayed in the complaint; and that the Sun spouses were buyers in good faith for value. The Revilla spouses responded that forgery was correctly found by the lower courts, prescription/laches did not apply because actions to declare the inexis...(Subscriber-Only)
Issues:
- Is the Revilla spouses’ cause of action barred by prescription or laches?
- Did the trial court acquire jurisdiction when the Revilla spouses paid docket fees computed on the P50,000 prayer despite later mentioning a P12,000,000 value at pre‑trial?
- Did the Court of Appeals err in upholding reinstatement and reconveyance of the property to the Revilla spouses (i.e., were the Kasulatan and subsequent transfers valid, and was petitioner entitled to rely on good fai...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)