Case Digest (G.R. No. 173211)
Facts:
In 1954, Ireneo Mendoza, married to Salvacion Fermin, acquired a 240-square-meter parcel in Bagong Pag-asa, Quezon City, covered by TCT No. 106530. He had two daughters, Josefina and Martina (the respondents), and raised his niece, Angelina Mendoza-Intac, from age three until her marriage to Mario Intac. On October 25, 1977, with Salvacion’s consent, Ireneo executed a deed of absolute sale of the property in favor of Spouses Mario and Angelina Intac for a stated consideration of ₱60,000. Despite the transfer, Ireneo’s family retained possession and continued paying taxes. Ireneo died in 1982; Salvador later passed away, yet the respondents remained on the land, collecting rents. In 1993, respondents discovered that TCT No. 106530 had been cancelled and replaced by TCT No. 242655 in the name of Spouses Intac. On February 22, 1994, they filed a complaint for cancellation of title and reconveyance before the RTC. On April 30, 2002, the RTC declared the deed an equitable mortgage, oCase Digest (G.R. No. 173211)
Facts:
- Background of the Parties and Property
- Ireneo Mendoza (Ireneo), married to Salvacion Fermin, purchased in 1954 a 240-sqm lot in Bagong Pag-asa, Quezon City, covered by TCT No. 106530 (later TCT No. 242655).
- Ireneo had two daughters (Josefina and Martina) by a prior marriage and reared his niece, Angelina Mendoza-Intac (Angelina), from age three until her marriage to Mario Intac.
- Alleged Sale and Continued Possession
- On October 25, 1977, with Salvacion’s consent, Ireneo executed a Deed of Absolute Sale in favor of Spouses Mario and Angelina Intac (Spouses Intac), purportedly for ₱60,000.
- Despite the sale, Ireneo’s family (including respondents Josefina and Martina) continued residing on the property and paying real estate taxes.
- Deaths and Filing of Complaint
- Ireneo died intestate in 1982; Salvacion died thereafter. Respondents remained in undisturbed possession, leasing portions and collecting rentals.
- In February 1994, respondents filed an action before the RTC for cancellation of TCT No. 242655 (issued in Spouses Intac’s names) and reconveyance of the property, alleging the 1977 sale was simulated and void.
Issues:
- Whether the October 25, 1977 Deed of Absolute Sale is a valid, enforceable sale or an absolutely simulated contract (void ab initio).
- Whether respondents’ action for cancellation of title and reconveyance is barred by prescription.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)