Case Digest (G.R. No. 156879)
Facts:
- The case concerns a residential land dispute in Quezon City, approximately 552.20 square meters in size.
- Narcisa Prado inherited the land from her deceased first husband, Patricio Prado, Sr.
- Following Patricio's death in 1959, Narcisa remarried Bonifacio Calpatura.
- To support her minor children, Narcisa entered into an Agreement of Purchase and Sale with her brother-in-law, Tomas Calpatura, Sr., on April 26, 1968, agreeing to sell the northern half of the property for P10,500.
- A Deed of Absolute Sale was executed by Narcisa in favor of Tomas on July 28, 1973.
- In 1976, Tomas' daughter built a duplex on the northern half, which was not contested by the respondents occupying the southern half.
- On April 8, 1991, the respondents filed a complaint to declare the sale null, asserting it was a mortgage and that Narcisa lacked authority to sell.
- The Regional Trial Court dismissed the complaint, affirming the sale's validity.
- The Court of Appeals modified the ruling, stating the sale was valid only for Narcisa's 1/7 undivided share.
Issue:
- (Unlock)
Ruling:
- The Supreme Court partly affirmed the Court of Appeals' decision, ruling that Narcisa Prado is entitled to 9/14 of the residential land.
- The Court upheld the validity of the sale of the undivided one-half portion by Narcisa to Tomas Calpatura, Sr...(Unlock)
Ratio:
- The Supreme Court established that property acquired during marriage is presumed to belong to the conjugal partnership unless proven otherwise.
- Narcisa's assertion of purchasing the property with her own funds was acknowledged, but she recognized in the sale documents that it was part of her conjugal share.
- The court highlighted the parole evidence rule, which prevents altering written agreements with oral tes...continue reading
Case Digest (G.R. No. 156879)
Facts:
The case centers around a dispute regarding the ownership and sale of a residential land located at 19th Avenue, Murphy, Quezon City, which spans approximately 552.20 square meters. The original owner of the land was Narcisa Prado, who inherited it from her first husband, Patricio Prado, Sr., who died on December 19, 1959. After his death, Narcisa remarried Bonifacio Calpatura. To provide for her minor children, Narcisa entered into an Agreement of Purchase and Sale with her brother-in-law, Tomas Calpatura, Sr., on April 26, 1968, agreeing to sell the northern half of the property for P10,500. This agreement was followed by a Deed of Absolute Sale executed by Narcisa in favor of Tomas on July 28, 1973. In 1976, Tomas' daughter, Flordeliza Calpatura Flora, constructed a two-storey duplex on the northern half of the property, which was not contested by the respondents, who occupied the southern half. However, on April 8, 1991, the respondents filed a complaint seeking a declaration of nullity of the sale, contending that the transaction was a mortgage rather than a sale and that Narcisa lacked the authority to sell the property. The Regional Trial Court dismissed the complaint, affirming the validity of the sale. Subsequently, the Court of Appeals modified thi...