Title
Guison vs. Heirs of Terry
Case
G.R. No. 191914
Decision Date
Aug 9, 2017
A 1995 land sale was revoked in 1996 due to lack of consideration, but a 2000 partition agreement allocated 3,000 sqm to the buyer. The Supreme Court voided the agreements for lack of price certainty, upheld third-party buyers' rights, and ordered repayment to prevent unjust enrichment.
conveyance agreements
parcel of land
null and void
A

Case Digest (G.R. No. 191914)

Facts:

  • Contractual Transactions and Instruments
    • Deed of Absolute Sale (March 14, 1995)
      • Executed by Angeles Vargas in favor of respondent Lorenio Terry.
      • Pertained to an agricultural lot in Moonwalk, Danicop, Catanduanes (1.3894 hectares, identified as Lot No. 10628-pt).
      • Vargas acknowledged receipt of P5,557.60 as payment.
    • Subsequent Dispositions by Terry
      • Between September and December 1995, portions of the lot were sold to third parties:
        • Jose U. Alberto III purchased 583 square meters.
ii. Alona M. Guerrero acquired 400 square meters. iii. Lino Gianan received 200 square meters.
  • Agreement of Revocation of Sale (January 22, 1996)
    • Executed by Vargas and Terry to correct an error in the sale covering the entire lot.
    • Revoked the sale of 1.0894 hectares, retaining only a 3,000-square meter portion for conveyance to Terry.
    • Provided that the precise location of the 3,000 square meters would be determined later by a separate document.
  • Partition Agreement (May 3, 2000)
    • Entered into by the heirs of Angeles Vargas (represented by petitioner Agnes V. Guison) and respondent Terry for physically segregating the property.
    • Detailed the subdivision of Lot No. 10628-part into:
      • A southwestern portion of 2,600 square meters.
ii. A western portion of 400 square meters. iii. An aggregate allocation of 3,000 square meters to Terry, which included already sold portions.
  • Recognized the remaining area as belonging to the Vargas heirs.
  • Further Sales and Resulting Ownership
    • Terry, after the Partition Agreement, sold additional portions to:
      • Alex Laynes (500 square meters)
ii. Elisa Sarmiento (400 square meters) iii. Fe Alberto (400 square meters) iv. Medin Francisco (200 square meters)
  • Eddie Alcantara (100 square meters)
vi. Oswaldo de Leon (200 square meters)
  • These series of transactions left Terry with ownership of only 17 square meters of the original lot.
  • Estate Settlement and Subsequent Ownership
    • An Extrajudicial Settlement of Estate Among Heirs (May 8, 2000) allocated Lot 10628-pt to petitioner Agnes V. Guison as part of the Vargas estate.
  • Initiation of Litigation
    • On November 16, 2006, petitioner filed a Complaint for annulment of contracts, accion publiciana, and damages against Terry and the subsequent purchasers.
    • The challenged instruments included:
      • The original Deed of Absolute Sale.
ii. The Agreement of Revocation of Sale. iii. The Partition Agreement. iv. All subsequent Deeds of Absolute Sale executed by Terry to third parties.
  • The petitioner argued that the absence of consideration rendered the original instruments void, which in turn vitiated the Partition Agreement.
  • Procedural Developments in Lower Courts
    • Respondents (including Terry and the third-party buyers) filed Answers or counterclaims asserting their reliance on the Partition Agreement as evidence of Terry’s right.
    • The Regional Trial Court (RTC) ruled in favor of the petitioner by declaring the instruments void for lack of monetary consideration and a failure in the meeting of the minds.
    • Some respondents sought reconsideration or filed appeals:
      • Certain respondents (e.g., Alcantara, De Leon, Gianan, and the Spouses Francisco) pursued reconsideration, which was denied.
ii. Others (such as Terry, Alberto, and Sarmiento) opted to file a Notice of Appeal, elevating the matter to the Court of Appeals (CA).
  • Court of Appeals and Supreme Court Involvement
    • In its Decision dated March 19, 2009, the CA reversed the RTC ruling by:
      • Upholding the validity of the Revocation and Partition Agreements, based on the parties’ intent to transfer a 3,000-square meter portion.
ii. Ruling that petitioner’s claims were barred by the doctrines of laches and estoppel.
  • Petitioner elevated the issue to the Supreme Court by filing a Petition for Review, maintaining that:
    • The Revocation and Partition Agreements were void for lack of consideration.
ii. The alleged delay in asserting her claim did not satisfy the requisites for the application of laches.
  • Subsequent developments included the death of Terry on July 7, 2012, with his heirs substituted as respondents.

Issues:

  • Validity of the Contracts
    • Whether the Court of Appeals erred in refusing to annul the Revocation Agreement and the Partition Agreement on the ground of lack of consideration.
    • Whether the absence of an agreed “price certain” meant that there was no meeting of the minds necessary for a valid contract of sale.
  • Application of the Doctrines of Estoppel and Laches
    • Whether the CA correctly held that the petitioner’s claims were barred by laches due to her delay in asserting them.
    • Whether petitioner’s own representations (especially in executing the Partition Agreement) estopped her from later challenging the validity of the conveyance to Terry and third parties.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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