Case Digest (G.R. No. 152168)
Facts:
Heirs of the Late Spouses Aurelio and Esperanza Balite, et al. v. Rodrigo N. Lim, G.R. No. 152168, December 10, 2004, Supreme Court Third Division, Panganiban, J., writing for the Court.Petitioners are the eight children and heirs of the late spouses Aurelio and Esperanza Balite (collectively, the Balite heirs); respondent is Rodrigo N. Lim (the buyer). The dispute arose from a purported sale on April 16, 1996, by Esperanza Balite of a 10,000-square-meter portion (identified as Lot 243 in a subdivision sketch) of a 17,551-square-meter parcel covered by Original Certificate of Title No. 10824. The Deed of Absolute Sale recited a purchase price of P150,000, but the parties executed a contemporaneous Joint Affidavit declaring the real purchase price to be P1,000,000, payable in installments. Respondent took possession, made improvements, and payments evidenced by receipts and checks; capital gains tax was paid based on the P150,000 stated price and the Register of Deeds (RD) later issued Transfer Certificate of Title (TCT) No. 6683 in respondent’s name.
After Esperanza’s death (October 31, 1996), several heirs protested the sale, wrote the RD requesting it to hold registration in abeyance, and the heirs filed a civil action (Regional Trial Court (RTC), Civil Case No. 920) for annulment of sale, quieting of title, injunction and damages. The RTC dismissed the complaint, holding the sale valid as to Esperanza’s pro indiviso share and ordered cancellation of the lis pendens. On appeal, the Court of Appeals (CA) reversed the trial court and rendered judgment limiting the sale to Esperanza’s undivided share (9,751 sq.m.), ordered cancellation of TCT No. 6683 and issuance of a new title over the entire original parcel with co-ownership shares (each petitioner 975 sq.m.; respondent 9,751 sq.m.), and directed respondent to pay petitioners P120,000. The CA also held the true consideration was P1,000,000 (as per the Joint Affidavit) and rejected the contention that the deed was an equitable mortgage.
The Balite heirs filed a Petition for Rev...(Subscriber-Only)
Issues:
- Was the trial court’s rejection of petitioners’ Amended Complaint proper and, relatedly, was the bank properly impleaded or an indispensable party?
- Is TCT No. 6683 in the name of respondent null and void or otherwise ineffective by reason of the lis pendens annotation and the timing of registration after Esperanza’s death?
- Is the Deed of Absolute Sale of April 16, 1996 void or null because the price in the deed was falsified and the transaction was intended to evade taxes or had an unlawful cause?
- Did the Court of Appeals err in refusing to treat the transaction as an equitable mortgage under Articles 1602 and 1604 of the Civil Code due to alleged inadequacy of consideration?
- What was respondent’s outstanding liability under the sale — was it P120,000 as the CA held, or a different amount as claimed ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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