Case Digest (G.R. No. 256633)
Facts:
Grand Planters International, Inc. v. Maine City Property Holdings Corp., G.R. No. 256633, August 22, 2022, Supreme Court Second Division, Lazaro‑Javier, J., writing for the Court.Petitioners below, Maine City Property Holdings Corp. (MCPHC) and its president Joel G. Yap filed Civil Case No. 1141‑ML before the Regional Trial Court (RTC), Branch 94, Mariveles, Bataan, against Grand Planters International, Inc. (GPII), Arlene Bernardo, the Heirs of Leonardo Serios, and the Register of Deeds of Bataan seeking: nullification of the 2014 Extrajudicial Settlement with Sale and the 2015 Deed of Sale; affirmation of a 2006 Deed of Sale; cancellation of TCT No. 038‑2016000719 (GPII) and TCT No. 038‑2015000040 (Bernardo); reinstatement of OCT No. 16; and attorney’s fees and damages. MCPHC and Yap alleged that the property (Lot No. 638) had been sold to them in 2006, the owners duplicate of OCT No. 16 was delivered to Yap, and that the Heirs later caused the fraudulent issuance of a second owner’s copy and sold the property to Bernardo, who in turn sold to GPII.
The Heirs answered that their transaction with MCPHC was a contract to sell (not an absolute sale), that they were induced to sign documents and surrender OCT No. 16 to Yap, and that they were not paid in full; they later executed the 2014 extrajudicial settlement and affidavit of loss and obtained reissuance of an owner’s copy by CAD proceedings in RTC‑Balanga. Bernardo and GPII each pleaded, inter alia, status as innocent purchasers for value and that due diligence in public registries did not reveal any encumbrance or the asserted 2006 transaction.
At pre‑trial the parties stipulated, among other things, to the existence of the 2006 Deed of Sale between MCPHC and the Heirs; authenticity of signatures (with the qualification that some signatures were signed in blank); the due execution and authenticity of OCT No. 16; the turn‑over of OCT No. 16 to Yap; and that the subject property was originally covered by OCT No. 16. Based on those stipulations and documentary exhibits (including OCT No. 16, the 2006 deed, the affidavit of loss, the 2014 extrajudicial settlement, the TCTs, and the deeds of sale), MCPHC and Yap filed an Omnibus Motion to Render Judgment on the Pleadings and/or for Summary Judgment.
By Order dated May 31, 2018 and Decision dated November 23, 2018, the RTC granted the omnibus motion and rendered summary judgment: it declared void the 2014 sale to Bernardo and the 2015 sale to GPII; declared the 2006 deed valid; directed cancellation of the TCTs issued to Bernardo and GPII; and reinstated OCT No. 16. GPII appealed to the Court of Appeals (CA‑G.R. CV No. 112409), which affirmed the summary judgment in a Decision dated September 25, 2020 and de...(Subscriber-Only)
Issues:
- Was the grant of summary judgment proper on the basis of the parties’ stipulations and documentary evidence?
- Did respondents (MCPHC and Yap) establish that there was no genuine issue of material fact concerning (a) the nature and effect of the 2006 Deed of Sale and (b) GPII’s claim of being an innocent purchaser for value?
- May the presumption of regularity accorded to a notarized, unregistered deed conclusively resolve the parties’...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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