Case Digest (G.R. No. 119064)
Facts:
In 1998, Erlinda Dinglasan-Delos Santos and her husband Pedro Delos Santos executed a promissory note dated April 8, 1998 for ₱100,000.00 in favor of Teresita Dinglasan-Abejon, secured by a mortgage over their 43.50 sqm property in Bangkal, Makati (TCT No. 131753). After Pedro’s death in 1989, Erlinda purportedly agreed to sell the same parcel to Teresita for ₱150,000.00. On July 8, 1992, the parties signed a Deed of Sale and a Release of Mortgage, leading to the issuance of TCT No. 180286 in Teresita’s name (married to Alberto Abejon). Respondents constructed a three-storey building worth ₱2,000,000.00 on the land. Petitioners, who remained in possession, later discovered Pedro’s signature on the sale documents to be forged. Respondents demanded payment of ₱150,000.00 and ₱2,000,000.00 but petitioners refused, prompting a Complaint for Cancellation of Title with collection of sum before the RTC. During pre-trial, the parties stipulated that the sale and mortgage documents wereCase Digest (G.R. No. 119064)
Facts:
- Factual Background
- In April 1998, petitioners Erlinda Dinglasan-Delos Santos and her late husband Pedro borrowed ₱100,000 from Teresita Dinglasan-Abejon, secured by a mortgage annotated on TCT No. 131753 covering a 43.50-sqm parcel in Makati City.
- After Pedro’s death in 1989, a purported Deed of Sale and Release of Mortgage dated July 8, 1992 was registered, cancelling TCT No. 131753 and issuing TCT No. 180286 in Teresita’s name; respondents then built a three-storey building worth ₱2,000,000 on the land.
- Petitioners denied the sale’s validity, alleging forgery of Pedro’s signature, and refused demands for ₱150,000 (loan plus ₱50,000 consideration) and ₱2,000,000 (building cost).
- Procedural History
- Respondents filed a Complaint for Cancellation of Title with collection of sum of money before the RTC, and during pre-trial the parties stipulated that the 1992 Deed and Release were forged, titles should be restored to petitioners, petitioners occupied the land and building, the ₱100,000 loan remained unpaid, and respondents paid for the building.
- The RTC (Aug 25, 2010) declared the Deed and Release null and void, reinstated TCT No. 131753, and ordered petitioners to pay:
- ₱100,000 plus 12% interest from July 8, 1992;
- ₱2,000,000 for the building; and
- ₱100,000 attorney’s fees.
- The CA (Mar 19, 2014) affirmed with modifications, adjusting interest to 12% from Nov 25, 1997 on the loan, 6% on the building cost from finality, and cancelling the Release of Mortgage; its denial of reconsideration (Dec 11, 2014) led to this SC petition.
Issues:
- Whether petitioners are liable for the ₱100,000 loan obligation.
- Whether petitioners must return the ₱50,000 excess consideration.
- Whether petitioners must reimburse respondents for the ₱2,000,000 building cost.
- Whether attorney’s fees may be awarded.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)