Case Digest (G.R. No. 200274)
Facts:
Melecio Domingo v. Spouses Genaro Molina and Elena B. Molina, G.R. No. 200274, April 20, 2016, Supreme Court Second Division, Brion, J., writing for the Court.Petitioner Melecio Domingo (Melecio) sued the spouses Genaro Molina and Elena B. Molina (the spouses Molina; later substituted in the record), seeking annulment of title and recovery of ownership over an undivided one-half interest in a parcel in Camiling, Tarlac. The spouses Molina were named respondents; during the pendency of the case the spouses died and were substituted in the record (the record also reflects substitution by an heir). Melecio filed a Rule 45 petition for review on certiorari from the Court of Appeals decision.
In 1951 Anastacio and Flora Domingo bought an undivided one-half interest in the subject lot (annotated on OCT No. 16354). Flora died in 1968. During his lifetime Anastacio incurred debts to the spouses Molina; on September 10, 1978—ten years after Flora's death—Anastacio purportedly sold his rights and interests in the property to the spouses Molina, and the sale was annotated on the OCT. Anastacio died in 1986. The sale was later registered under TCT No. 272967 in 1995.
Melecio learned of the transfer and on May 17, 1999 filed a Complaint for Annulment of Title and Recovery of Ownership, alleging that the sale was invalid because conjugal property could not be sold without the deceased spouse Flora's consent, that the transfer documents were falsified or nonexistent, and that he had been in possession of the property after Anastacio's death. At trial Melecio presented testimony from the Register of Deeds' Records Officer (who could not locate the alleged transfer instrument and noted that the annotation was entered when a relative of Genaro Molina was Register) and from his nephew George Domingo (who testified to occupancy by several caretakers). The spouses Molina produced testimony (Jaime Garlitos) that Elena Molina permitted occupants, that the respondents paid taxes and exercised ownership attributes, and that Melecio knew of the transactions; counsel for the respondents later conceded that Anastacio had delivered the title in payment of a Php30,000 debt.
The Regional Trial Court (RTC) dismissed Melecio's complaint, finding he failed to prove Anastacio did not validly sell his interest and concluding the sale was necessary to answer conjugal liabilities; the RTC denied reconsideration. On appeal the Court of Appeals (CA) in an August 9, 2011 decision (CA-G.R. CV No. 94160) affirmed the RTC in toto: the CA found Melecio did not prove fraud, relied on the OCT annotation, held that Flora's earl...(Subscriber-Only)
Issues:
- Is the sale by Anastacio of an undivided interest in conjugal property to the spouses Molina without Flora's consent valid and legal?
- Was the transfer of the disputed property to the spouses Molina attended with fraud sufficient to invalidate their ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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