Case Digest (G.R. No. 236804)
Facts:
This case involves the petitioners, the heirs of the late spouses Alejandro Ramiro and Felicisima Llamada—namely Henry L. Ramiro, Merlyn R. Taguba, Marlon L. Ramiro, Maridel R. Santella, Wilma L. Ramiro, Vilma R. Cielo, and Carolyn R. Cordero—who appealed a court ruling concerning Lot 329, Cad-600, a property covered by Original Certificate of Title (OCT) No. P-12524, situated in Gov. Generoso, Davao Oriental. Respondent spouses Eleodoro and Verna Bacaron filed a civil case (Civil Case No. 1966 (045)) before the Regional Trial Court (RTC) of Lupon, Davao Oriental, against the petitioners. They claimed that the late Alejandro Ramiro was the registered owner of the subject property and that the late spouses Ramiro sold the property to them via a Deed of Sale executed on October 20, 1991. The Bacarons asserted that they took possession of the property after the sale but the property was previously mortgaged to the Development Bank of the Philippines (DBP). They allege that they re
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Case Digest (G.R. No. 236804)
Facts:
- Parties and Origin of the Case
- Petitioners are the heirs of the late spouses Alejandro Ramiro and Felicisima Llamada, namely Henry L. Ramiro, Merlyn R. Taguba, Marlon L. Ramiro, Maridel R. Santella, Wilma L. Ramiro, Vilma R. Cielo, and Carolyn R. Cordero.
- Respondents are spouses Eleodoro and Verna Bacaron.
- Trial Court Proceedings
- Spouses Bacaron filed Civil Case No. 1966 (045) before the Regional Trial Court (RTC) of Lupon, Davao Oriental, against the petitioners.
- In their amended complaint, spouses Bacaron alleged:
- The late Alejandro Ramiro was the registered owner of Lot 329, Cad-600, with an area of 48,639 square meters, covered by Original Certificate of Title (OCT) No. P-12524.
- Alejandro Ramiro and Felicisima Llamada sold the property to spouses Bacaron via a Deed of Sale executed on October 20, 1991.
- Spouses Bacaron took possession of the property after the sale.
- The property was previously mortgaged by spouses Ramiro to the Development Bank of the Philippines (DBP).
- Spouses Bacaron paid the DBP P430,150.00 to redeem the property.
- Petitioners forcibly dispossessed spouses Bacaron of the property in June 1998.
- Defenses and Trial Court Decision
- Petitioners denied the allegations and raised affirmative defenses:
- The RTC lacked jurisdiction, since the case involved recovery of possession.
- The instrument called a Deed of Sale should be construed as an equitable mortgage.
- Laches barred the respondents’ complaint.
- After trial, the RTC rendered a July 13, 2007 Decision in favor of spouses Bacaron, holding:
- The Deed of Sale dated October 20, 1991 was valid despite the loss of the original document; competent secondary evidence was presented.
- The purchase price corresponded broadly to the amount paid to DBP.
- Ordered defendants to execute a Deed of Extra-Judicial Partition confirming the sale, directed registration in favor of plaintiffs, ordered defendants to vacate and restore possession, and pay attorney’s fees.
- Court of Appeals Proceedings
- Petitioners appealed to the Court of Appeals (CA), arguing:
- The main relief was recovery of possession, but spouses Bacaron failed to allege assessed value; hence RTC lacked jurisdiction under B.P. Blg. 129 as amended by R.A. No. 7691.
- The CA, on October 19, 2010, affirmed the RTC Decision in toto, holding:
- The RTC had jurisdiction because the complaint included causes of action incapable of pecuniary estimation (declaration of validity of Deed of Sale, specific performance, damages, attorney’s fees, injunction).
- Petitioners failed to prove equitable mortgage since they forcibly took possession in 1998; payment of realty taxes was irregular and insufficient as proof.
- Petitioners failed to prove laches.
- A motion for reconsideration by petitioners was denied on May 3, 2011.
- Petition for Review before the Supreme Court
- Petitioners filed a Rule 45 petition challenging the CA decisions, raising:
- Whether the RTC acquired jurisdiction over the subject matter of the action.
- Whether the Deed of Sale should be treated as an equitable mortgage.
- Whether spouses Bacaron’s claims are barred by laches.
Issues:
- Whether the Regional Trial Court acquired jurisdiction over the subject matter of the action.
- Whether the Deed of Sale dated October 20, 1991 should be construed as an equitable mortgage.
- Whether spouses Bacaron’s claims are barred by laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)