G.R. No. 177505 - Heirs of Medina vs. Natividad

In 1969, five co-owners of a parcel of land in Guimba, Nueva Ecija (Lot 1199, Cad-162, Guimba Cadastre) agreed to divide and allot the property among themselves.
A sketch plan indicated the respective portions; notably, Gorgonio D. Medina received two portions—one exclusively and one jointly with Tirso Medina and Pacifico M. Ruiz.

On 29 March 1972, Gorgonio D. Medina, as a predecessor-in-interest, executed a Deed of Absolute Sale selling his 1/3 share (the share in the second portion) to Bonifacio Natividad.
A partition suit (Civil Case No. 781-G) was instituted by Tirso Medina against the co-owners, including Gorgonio Medina and Bonifacio Natividad, leading to a compromise agreement submitted to the court.

On 20 November 1989, the RTC approved a Compromise Agreement resolving differences among the co-owners, thereby ending the community of ownership by subdividing the property into several lots.
The agreement detailed the allocation of six lots, specifying which lot corresponded to which party—for example, Lot No. 1 (480 sq. m.) for Bonifacio Natividad and Lot No. 6 (369.29 sq. m.) for Gorgonio Medina.
On 8 October 1991, following a survey that re-divided Lot 1199 into Lots A–F, the subdivisions were mapped to the adjudicated lots, with no change in designation but with modified areas.

Lot 1199-C, measuring 371 square meters and adjudicated to Gorgonio Medina, was registered under TCT No. NT-230248, effectuating the transfer of title.
On 11 June 2001, Bonifacio Natividad, through his alleged attorney-in-fact Philip M. Natividad, filed a Complaint for Annulment of TCT No. NT-230248 and for damages, challenging the registration and claiming a right over a 1/3 share of the land.

Defendants (the heirs of Gorgonio Medina) raised issues including lack of legal capacity of Philip Natividad by contending that the special power of attorney (SPA) did not confer the authority to sue.
The case saw various motions: a Motion for Bill of Particulars (granted), a Motion for Leave to Admit an Amended Complaint (which impleaded all heirs), and a Motion to Dismiss (denied by the trial court).
During pre-trial, the parties stipulated relevant facts about the property, its title, and the issues regarding the relationship between the deed of sale and the adjudicated lots.

The trial court rendered a decision on 10 December 2003, in favor of Bonifacio Natividad, ordering the defendants to convey a 1/3 portion of the lot (based on TCT No. NT-230248) together with an accounting of income derived.
On the issue of Philip Natividad’s authority, the trial court upheld the validity of the SPA, noting its notarization by a notary public in the State of Washington, USA, despite questions regarding its authentication.
The Court of Appeals (decision dated 20 November 2006) modified the remedy, directing the conveyance of only 90 square meters (i.e., 1/3 of 270 square meters) based on its interpretation of the trust relationship.
Subsequent motions for reconsideration were denied, prompting Bonifacio Natividad to elevate the case to the Supreme Court.

Central to the dispute was whether the SPA executed in Washington, USA, was admissible in evidence, given that it lacked the requisite consular authentication as required under Section 25 (now Section 24) of the Rules of Court.
The question of whether such technical deficiency deprived the lower courts of jurisdiction over the real party in interest became pivotal.

Whether the Compromise Agreement approved by the RTC in Civil Case No. 781-G effectively novated the Deed of Absolute Sale executed on 29 March 1972.
Whether the deed of sale may be enforced despite the fact that the lot portion described therein differs from the lot covered by TCT No. NT-230248.
Whether Bonifacio Natividad is estopped by laches from asserting his rights over the property.
Whether the registration of Lot 1199-C in the name of Gorgonio Medina occurred in fraud of Bonifacio Natividad’s rights.
Whether a constructive (or implied) trust was established between Gorgonio Medina and Bonifacio Natividad.
Whether Bonifacio Natividad’s cause of action has prescribed under the applicable prescriptive period.
Whether the complaint sufficiently states a cause of action.
Whether Philip M. Natividad was duly authorized to represent his father, Bonifacio Natividad, given that the SPA was executed abroad and did not comply with the authentication requirements.