Case Digest (G.R. No. 125539)
Facts:
The case involves a dispute between the heirs of Ferdinand A. Roxas (petitioners: Angela Margarita T. Roxas, Dyan Paula T. Roxas, Michael Jude T. Roxas, and Maria Katrina T. Roxas) and the heirs of Melania Roxas (respondents: Manuel A. Roxas, Maria Rosario Roxas-Ureta, Alexander A. Roxas, Salome Roxas-Pantaleon, Paul Gerardo Roxas, Elaine Roxas-Gamboa, Ma. Imelda Roxas-Cruz, and David Anthony Roxas). Antonio and Melania Roxas were married and had several children including Ferdinand, Manuel, and Paul among others. In 1970, Melania’s cousin executed a Deed of Absolute Sale (DOAS) transferring ownership of a 500-square-meter parcel of land in Loakan, Baguio City (the subject lot) to Ferdinand for PHP 5,000. A Transfer Certificate of Title (TCT) was issued in Ferdinand’s name. Melania built a family house on the lot used for vacations and residence by some children. From 1990–1995 Melania rented part of the property, and several family members lived there. Antonio died in 1995; Fer...Case Digest (G.R. No. 125539)
Facts:
- Parties and Background
- Petitioners: Heirs of Ferdinand A. Roxas (Angela Margarita T. Roxas, Dyan Paula T. Roxas, Michael Jude T. Roxas, Maria Katrina T. Roxas).
- Respondents: Heirs of Melania Roxas (Manuel A. Roxas, Maria Rosario Roxas-Ureta, Alexander A. Roxas, Salome Roxas-Pantaleon, Paul Gerardo Roxas, Elaine Roxas-Gamboa, Ma. Imelda Roxas-Cruz, David Anthony Roxas).
- Antonio Roxas and Melania Roxas are parents of Ferdinand and the other heirs.
- Property and Transaction
- In 1970, Felicisma Garcia (Melania's cousin) executed a Deed of Absolute Sale (DOAS) for a 500 sqm land in Loakan, Baguio City.
- The title was issued in Ferdinand's name (TCT No. T-16657).
- Melania built a house on the lot; family used it as a vacation house and residence.
- Possession and Use
- Melania rented part of the property to Alfredo Sison (1990–1995).
- Paul Roxas started residing there in 1991 with his family.
- Deaths
- Antonio Roxas died April 1, 1995.
- Ferdinand died September 18, 2004.
- Melania died January 1, 2011.
- Litigation Initiation
- On November 11, 2014, Heirs of Melania filed a complaint to declare the DOAS void and cancel Ferdinand's title.
- Allegations: Melania was the true purchaser but placed title in Ferdinand's name to protect children’s interests given Antonio's illegitimate children.
- Heirs of Ferdinand countered that Ferdinand is true owner, purchased with help from parents, paid taxes, allowed Melania to rent and use property.
- Family Corporation and Donations
- Antonio and Melania transferred assets to family corporation Mel-Rox Realty Inc. in 1988.
- In 1997, a "Donation Document" was executed, distributing properties/money among children; Ferdinand received the subject property, others received money or property.
- Trial Court (RTC) Decision
- Dismissed Complaint of Melania's Heirs for lack of merit.
- Held transaction not simulated; Ferdinand held title in his name as owner.
- Found valid contract; Melania and Antonio were true purchasers but gave subject property to Ferdinand.
- Heirs of Melania acted in bad faith; ordered them to pay attorney's fees.
- Court of Appeals (CA) Decision
- Reversed RTC decision.
- Declared DOAS a relatively simulated contract; Melania was true owner.
- Ordered cancellation of Ferdinand's title and issuance of a new title in Melania's name.
- Held donation to Ferdinand invalid for failing formal donation requirements.
- Ruled Ferdinand held subject lot in trust for Melania per Article 1448 of the Civil Code.
- Petition to the Supreme Court
- Heirs of Ferdinand filed petition challenging CA ruling.
- Argued Donation Document confirmed ownership in Ferdinand.
- Asserted possession of title, tax payments and other evidence prove ownership.
- Claimed Heirs of Melania failed to prove trust or ownership claim.
Issues:
- Whether the Court of Appeals erred in ruling that Ferdinand was merely holding the subject lot in trust for Melania.
- Whether the disputed property was donated to Ferdinand by Melania under the presumptions of Article 1448 of the Civil Code.
- Whether compliance with formal donation requirements under Articles 748 and 749 of the Civil Code is necessary in a presumed donation under Article 1448.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)