Title
Garcia vs. Valera
Case
G.R. No. L-3072
Decision Date
Apr 18, 1951
The court upheld the validity of a homestead sale, reversing the nullification judgment due to insufficient evidence from the plaintiffs.
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Case Digest (G.R. No. L-3072)

Facts:

  • On August 2, 1934, Marcelo Uson received homestead patent No. 28199 for land in Barat, Bambang, Nueva Vizcaya.
  • Original Certificate of Title No. 1291 was issued to Uson on October 31, 1935.
  • Uson sold the land to Francisco Valera for P600 on August 10, 1939, and Transfer Certificate of Title No. 3313 was issued to Valera.
  • Marcelo Uson passed away in 1944.
  • On October 22, 1948, Uson's wife, Flaviana Garcia, and their two minor children filed a complaint against Valera, seeking reconveyance of the land and damages of P100 per year.
  • The trial court ruled the sale null and void, ordering Valera to return the property and receive P600 with legal interest.
  • Valera appealed the decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the trial court's judgment, declaring the sale from Marcelo Uson to Francisco Valera valid.
  • Valera was absolved from the...(Unlock)

Ratio:

  • The Supreme Court found the trial court's application of Commonwealth Act No. 456 to be incorrect.
  • The court noted that the appellees' witness did not definitively prove the sale lacked necessary approval at registration.
  • Valera's uncontradicted testimony indicated he had obtained a letter from the Bureau of Lands regarding the sale, which he presented to the Register of Deeds.
  • The issuance of T...continue reading

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