Case Digest (G.R. No. 168338)
Facts:
The case at hand involves Felipa Garbin as the petitioner and the spouses Antonio Julian and Casimira Garbin as respondents. The events unfolded in Tarlac, where Pablo Garbin and Leoncia Garbin, the parents of the petitioner and the private respondent Casimira, were the original owners of Lot 12712, measuring 25,681 square meters, as evidenced by Original Certificate of Title No. 33251. On October 31, 1955, they executed a "Deed of Absolute Sale of Real Estate," proposing to transfer ownership of the northern half of the lot to Casimira. Following this, Casimira registered an adverse claim over the property. Years later, on May 24, 1970, Pablo sold the entire lot to Felipa through another Deed of Sale, leading to the issuance of Transfer Certificate of Title No. 88932 in Felipa's name.On July 29, 1974, Felipa, alongside Pablo, filed an ejectment case against the respondents, which was initially decided in their favor at the Municipal Trial Court and affirmed by the Regional T
Case Digest (G.R. No. 168338)
Facts:
- Parties and Property
- Petitioner and Private Respondents
- Felipa Garbin is the petitioner who acquired the property through a subsequent sale.
- Private respondents include Casimira Garbin and her husband, Antonio Julian.
- Family relationships play a role: Pablo Garbin and his wife Leoncia are the parents of Felipa and Casimira.
- Subject Property
- The disputed property is Lot 12712, located in Camiling, Tarlac, with an area of 25,681 square meters.
- Pablo Garbin is shown as the original owner in the Original Certificate of Title No. 33251.
- Transactions and Conveyances
- The 1955 Transaction
- On October 31, 1955, Pablo Garbin and his wife executed a “Deed of Absolute Sale of Real Estate” purportedly conveying the undivided northern half of the lot to private respondent Casimira Garbin.
- Casimira subsequently registered an adverse claim over that portion of the property.
- The 1970 Transaction
- On May 24, 1970, Pablo Garbin sold the entire Lot 12712 to petitioner Felipa Garbin by virtue of a Deed of Sale.
- A new Transfer Certificate of Title (TCT No. 88932) was issued in favor of Felipa.
- Subsequent Litigations and Proceedings
- Ejectment Case
- On July 29, 1974, Felipa and Pablo Garbin filed an ejectment case against the private respondents.
- The Municipal Trial Court ruled against the private respondents, and the decision was affirmed by the Regional Trial Court.
- Private respondents filed for review with the Court of Appeals, which initially dismissed the petition, and a subsequent petition to the Supreme Court was likewise denied.
- Complaint for Annulment of Sale
- Before the ejectment case became final, on March 1, 1982, private respondents filed a complaint for annulment of sale, partition, and damages.
- The Regional Trial Court dismissed this complaint in favor of petitioner Felipa.
- The Court of Appeals later reversed the dismissal, basing its decision on the annotation of the adverse claim and an interpretation regarding the sale’s nature.
- The appellate decision allocated fractional interests: a 7/12 interest in the lot to private respondents and 5/12 to petitioner Felipa, based on the claim of a double sale.
- Contentions Raised in Petitioner’s Appeal
- Evidentiary Issues
- Petitioner argued that no evidence was furnished to prove the validity of the “Deed of Absolute Sale of Real Estate” executed in favor of the private respondents.
- It was contended that the mere annotation of the adverse claim is insufficient to validate and perfect the alleged prior sale.
- Testimonial and Documentary Rebuttals
- Testimony from Pablo Garbin in the ejectment case was cited, wherein he denied any knowledge of or involvement in selling the subject property to the private respondents.
- The Original Certificate of Title indicated sole ownership by Pablo Garbin and did not suggest that the lot was conjugal property.
- Prescription Argument
- Petitioner emphasized that private respondents’ cause of action for annulment had already prescribed.
- The significant lapse in time (over three decades since the execution of the deed) was raised as a matter of laches or prescriptive period.
Issues:
- Validity and Precedence of Registration
- Does the registration of the adverse claim by private respondents, which was done prior to petitioner’s registration, prevail over the subsequently registered title of petitioner Felipa?
- Is the mere annotation of an adverse claim sufficient to affect title despite the absence of a duly registered conveyance?
- Validity of the Alleged Prior Sale
- Can the alleged sale in favor of private respondents be deemed valid given that:
- There is an absence of evidence confirming the validity of the 1955 Deed of Absolute Sale?
- Pablo Garbin’s testimony repudiates the occurrence of such a sale?
- What is the role of completing all registration steps (such as final annotation) in establishing legal title?
- Prescription and Laches
- Has the delay (spanning 28 to 36 years) in asserting the rights under the adverse claim rendered the private respondents’ cause of action barred by prescription or laches?
- Do principles of estoppel and unexcused negligence in asserting rights apply in this case?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)