Case Digest (G.R. No. 228999)
Facts:
In Ana de Joya et al. v. Madlangbayan et al. (G.R. No. 228999, April 28, 2021), petitioners Ana and Ciriaco de Joya, Lerma and Mario Castillo, spouses Domingo and Leoncia Cordero, and Ricardo Villalobos, as heirs of Eufronio and Tarcila Cordero, owned two agricultural parcels in Barrio Concordia, Alitagtag, Batangas (Lot Nos. 5 and 6, TCT No. T-64767). By Special Power of Attorney (January 23, 1992) and General Power of Attorney (February 5, 1996), they authorized respondent Francisco P. Madlangbayan to sell the properties. In early April 1996, Madlangbayan received a P10 million counter-offer from spouses Dalida et al., which petitioners, through Madlangbayan’s April 10, 1996 letter, expressly rejected for failing to meet their non-negotiable P17 million price. On May 3, 1996, petitioners revoked Madlangbayan’s authority and on June 5, 1996 demanded return of the owner’s duplicate title. When Madlangbayan ignored these demands, petitioners filed an Affidavit of Adverse Claim (JCase Digest (G.R. No. 228999)
Facts:
- Parties and Subject Properties
- Petitioners: Ana de Joya and Ciriaco de Joya; Lerma R. Castillo and Mario Castillo; Spouses Domingo and Leoncia Cordero; and Ricardo Villalobos as surviving heir of Spouses Eufronio and Tarcila Cordero. Registered owners of Lot Nos. 5 (140,327 sqm) and 6 (31,465 sqm) in Barrio Concordia, Alitagtag, Batangas (TCT No. T-64767).
- Respondents: Francisco P. Madlangbayan (agent under Special and General POA), substituted by Rodesinda F. Madlangbayan and Maria Lourdes M. Montalbo; Spouses Dalida; Spouses Gullet; Spouses Ramos; Renato Go; Chollie Magnaye-Go; and their co-respondents.
- Antecedent Transactions and Litigation
- January 23, 1992 & February 5, 1996 – Petitioners grant Madlangbayan authority to sell the subject properties.
- April 1996 – Madlangbayan receives counter-offer from Spouses Dalida et al.; petitioners reject it by letter dated April 10, 1996, insisting on ₱17 million non-negotiable or better offers after May 31, 1996.
- May 3, 1996 – Petitioners execute Revocation of the POAs. June 5, 1996 – Demand for return of owner’s duplicate titles. July 1, 1997 – Affidavit of Adverse Claim filed.
- July 14, 1997 – Complaint for revocation of Madlangbayan’s authority; he replies sale already made. January 26, 1998 & March 21, 2000 – Supplemental complaints implead Spouses Dalida et al. and pray for damages.
- August 8, 2002 – RTC rules Madlangbayan and Dalida et al. are in good faith buyers; upholds Special Powers and Deed of Absolute Sale dated April 8, 1996.
- CA G.R. CV No. 77685 – Petitioners’ appeal; December 13, 2005 CA grants new trial on ground of newly discovered evidence (escrow CTD No. 7290; subsequent sale to Go et al.).
- June 27, 2007 – RTC (new trial) finds sale simulated, no good faith, voids all deeds, orders recovery of land, damages, rentals, attorney’s fees. Motion for Reconsideration denied.
- CA G.R. CV No. 90502 – December 17, 2009 CA grants Go et al.’s appeal, sets aside June 27, 2007 RTC Decision, remands for trial de novo; July 23, 2010 Motion for Reconsideration denied.
- October 25, 2012–2014 – Trial concludes; December 10, 2014 RTC Judgment reinstates petitioners’ rights, voids all deeds ab initio, orders respondents to vacate, pay damages, rentals, attorney’s fees; March 31, 2015 Motion for Reconsideration denied.
- CA G.R. CV No. 105049 – September 26, 2016 CA reverses RTC, declares April 8, 1996 Deed valid, orders petitioners to vacate; December 28, 2016 Motion for Reconsideration denied.
Issues:
- Whether the April 8, 1996 Deed of Absolute Sale was a valid contract or absolutely simulated.
- Whether judicial and extrajudicial admissions (letter rejecting counter-offer, inconsistent memoranda) establish non-consummation of sale as of April 8, 1996.
- Whether lack of proof of CTD No. 7290 or actual payment negates consideration for the purported sale.
- Whether the CA erred in disregarding the Best Evidence Rule and presuming existence of CTD No. 7290.
- Whether the CA should have applied the presumption of willful suppression of evidence due to respondents’ failure to produce the alleged ₱10 million.
- Whether the CA’s finding that CTD No. 7290 exists is supported by sufficient evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)