Facts:

• The case centers on a land sale dispute between Pedro Gonzales and Marcos Perez.
• The Municipality of Marikina, then part of Rizal Province, owned land subdivided into Lots A, B, and C.
• On January 14, 1966, the Municipal Council authorized the sale of Lots A and C through public bidding.
• Pedro Gonzales was the highest bidder on April 25, 1966, and a deed of sale was executed in his favor, pending approval by the Provincial Governor of Rizal.
• In September 1966, Pedro sold a portion of Lot C (Lot C-3) to Marcos Perez through a deed of sale that was not notarized.
• Both Pedro and Marcos later passed away.
• On February 7, 1992, the Municipality of Marikina executed a Deed of Absolute Transfer of Real Property over Lots A and C to the Estate of Pedro Gonzales, resulting in new titles.
• The heirs of Marcos Perez demanded reconveyance of the property, which the heirs of Pedro Gonzales refused, leading to a lawsuit for annulment and reconveyance.
• The RTC of Marikina dismissed the complaint, declaring the deed of sale void due to lack of notarization and ruling that Pedro only became the owner in 1992.
• The CA reversed this decision, declaring the sale valid and ordering reconveyance of the property to the heirs of Marcos Perez.
• The heirs of Pedro Gonzales filed a petition for review with the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the sale between Pedro Gonzales and Marcos Perez was valid and binding despite the lack of notarization.
2. The Supreme Court held that Pedro Gonzal...(Unlock)

Ratio:

• The Supreme Court emphasized that the lack of notarization does not render a contract of sale invalid but only affects its efficacy.
• Under Article 1358 of the Civil Code, the required form is not essential to the validity or enforceability of the transaction but merely for convenience.
• The approval of the Provincial Governor, as required under Section 2196 of the Revised Administrative Code, is part of the system of supervision and does...continue reading