Title
Heirs of Godines vs. Demaymay
Case
G.R. No. 230573
Decision Date
Jun 28, 2021
Heirs contested land ownership, claiming invalid sale by minor. SC upheld oral sale as valid, binding heirs due to partial payment, possession, and tax declaration.

Case Digest (G.R. No. 193256)

Facts:

Heirs of Anselma Godines, namely: Marlon, Francisco, Roque, Rosa and Alma, all surnamed Godines, v. Platon Demaymay and Matilde Demaymay, G.R. No. 230573, June 28, 2021, the Supreme Court Third Division, Hernando, J., writing for the Court. The petition seeks review of the Court of Appeals Decision dated August 16, 2016 and Resolution dated March 8, 2017 in CA-G.R. SP No. 133147.

Petitioners claim to be the forced heirs of Anselma Yuson Godines who died in 1968 owning a parcel at Divisoria, Cawayan, Masbate, originally tax-declared as 68 sq. meters under Tax Declaration No. 6111. Respondent spouses Platon and Matilde Demaymay were in possession of the land, asserting that Anselma had granted them use of the land in consideration of a loan and that an oral sale was consummated in January 1967 for P1,460.00; the parties agree no written contract was executed at the time.

In 1987 petitioners discovered Tax Declaration No. 7194 and later No. 7164 in Matilde’s name reflecting a larger area (332 sq. meters). Petitioners then filed a Complaint for Recovery of Ownership and Possession and Declaration of the Deed of Confirmation as Null and Void with Damages in the Regional Trial Court (RTC) of Cataingan, Masbate.

The RTC transferred the case to the Municipal Circuit Trial Court (MCTC), Placer, Masbate in 1995. The MCTC initially declared the spouses in default and later dismissed the case in 2008 for lack of RTC jurisdiction, but the RTC reversed and remanded. After additional proceedings and testimony (including that Anselma allegedly received initial and final payments and that a Deed of Confirmation was executed in 1970), the MCTC rendered judgment in favor of petitioners (June 19, 2013), declaring the heirs owners and annulling the Confirmation of Sale; the RTC affirmed that judgment on appeal (November 18, 2013).

Aggrieved, the spouses Demaymay filed a petition for review with the Court of Appeals under Rule 42, which, on August 16, 2016, reversed the lower courts and recognized the spouses as owners, orderin...(Subscriber-Only)

Issues:

  • Whether the Court of Appeals gravely erred in ruling that the heirs of Anselma are bound by the oral contract of sale allegedly executed in favor of the spouses De...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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