Case Digest (G.R. No. 23716)
Facts:
On June 1, 1908, the Government of the Philippine Islands, represented by the Director of Lands and with the approval of the Secretary of the Interior, sold a parcel of land identified as lot No. 665 of the Orion friar lands to Macario Santos for the amount of P1,244.37. The payment was structured in annual installments, with the final payment due on June 30, 1927. Macario Santos passed away prior to the initiation of the legal proceedings in this case. His widow, Emiliana Rivera, and their children were named as defendants. The plaintiffs in this case are the Director of Lands and certain alleged occupants of the lot who claim a right to purchase it under Act No. 1120, as amended. The plaintiffs filed a complaint seeking to have the sale to Macario Santos declared null and void, demanding that the defendants vacate the property and account for any benefits derived from it. The plaintiffs contended that the sale did not comply with the neces...
Case Digest (G.R. No. 23716)
Facts:
- Sale of Lot No. 665: On June 1, 1908, the Government of the Philippine Islands, through the Director of Lands and with the approval of the Secretary of the Interior, sold Lot No. 665 of the Orion friar lands to Macario Santos for P1,244.37. The payment was to be made in annual installments, with the last payment due on June 30, 1927.
- Death of Macario Santos: Macario Santos died before the filing of the complaint in this case. His widow, Emiliana Rivera, and his children are the defendants in this case.
- Payment of Installments: The installments were paid on time until the commencement of this action.
- Plaintiffs' Claims: The plaintiffs are the Director of Lands and alleged occupants of the lot who claim the right to purchase it under Act No. 1120, as amended. They seek to annul the sale to Macario Santos, alleging that the legal requisites for the sale were not complied with and that Macario Santos acted fraudulently in purchasing the land while serving as a Government agent in charge of its sale.
- Allegations of Fraud: Plaintiffs alleged that Macario Santos misled the occupants by stating that the entire purchase price and the value of improvements had to be paid in cash. However, evidence showed that the legal requisites were generally complied with, and the occupants were duly informed of the purchase conditions.
- Prescription of Action: The plaintiffs were aware of the alleged causes of nullity from the beginning, but they filed the complaint 13 years later. Under Act No. 190, the maximum period for bringing an action for annulment is 10 years.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Compliance with Legal Requisites: The Court found that the legal requirements for the sale were generally met, and the occupants were properly informed of the purchase conditions.
- Prescription of Action: The action for annulment was barred by prescription. Under Act No. 190, the maximum period for filing such an action is 10 years. Since the plaintiffs filed the complaint 13 years after becoming aware of the alleged defects, their claim was time-barred.
- Fraud Allegations: The Court did not find sufficient evidence to support the claim that Macario Santos acted fraudulently in purchasing the land.