Case Digest (G.R. No. 254452)
Facts:
Heirs of Ferdinand Roxas, namely: Angela Margarita T. Roxas, Dyan Paula T. Roxas, Michael Jude T. Roxas, and Maria Katrina T. Roxas v. Heirs of Melania Roxas, namely: 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, G.R. No. 254452, November 27, 2024, Supreme Court Third Division, Inting, J., writing for the Court.Antonio and Melania Roxas were spouses and parents of several children including Ferdinand A. Roxas and respondents (the Heirs of Melania). In 1970 Melania’s cousin sold a 500-sq.m. parcel in Loakan, Baguio City (the subject lot) by a Deed of Absolute Sale (DOAS) that named Ferdinand as buyer; Transfer Certificate of Title (TCT) No. T-16657 was thereafter issued in Ferdinand’s name. Melania built a house on the lot; from 1990–1995 she rented part of it and in 1991 Paul (one of Melania’s children) began residing there. Antonio died in 1995; Ferdinand died in 2004; Melania died in 2011.
On November 11, 2014, the Heirs of Melania sued for declaration of nullity of the DOAS and cancellation of TCT No. T-16657, alleging Melania was the true buyer who placed title in Ferdinand’s name to protect the property from Antonio’s illegitimate children. The Heirs of Ferdinand countered that Ferdinand was the true owner: they claimed Antonio and Melania provided money so Ferdinand could buy the lot; Ferdinand paid real property taxes and permitted Melania to build and rent the house; a document executed by officers of Mel-Rox Realty Inc. (the “Donation Document”) indicated the subject lot was given to Ferdinand.
The Regional Trial Court (Branch 5, Baguio City) in Civil Case No. 8146‑R ruled for the Heirs of Ferdinand (Decision dated January 19, 2017), dismissing the complaint and finding (inter alia) the transaction was not simulated, that Ferdinand held title as owner (or as donee under Article 1448), and that the Heirs of Melania acted in bad faith — awarding PHP 30,000 as attorney’s fees to defendants. The Heirs of Melania appealed.
The Court of Appeals (CA) in CA‑G.R. CV No. 109260 reversed (Decision dated February 13, 2020): it concluded Ferdinand was not the real buyer, characterized the DOAS as a relatively simulated contract, found the Donation Document did not satisfy formal requisites for donation under Articles 737/749 of the Civil Code, declared the lot part of Melania’s estate, and ordered cancellation of TCT No. T‑16657 and issuance of a new title in Melania’s name. The CA denied reconsideration (Resolution dated September 29, 2020).
The Heirs of Ferdinand filed a Petition for Review on Certiorari under Rule 45 before the Suprem...(Pro-only)
Issues:
- Did the Court of Appeals err in ruling that Ferdinand merely held the subject lot in trust for Melania (i.e., that no valid donation to Ferdinand occurred under Article 1448 of the Civil Code)?
- If the presumption of donation under Article 1448 applies, must that presumed donation still comply with the formal requirements for donations under Articles 748 and ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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