Case Digest (G.R. No. 244667-69)
Facts:
In Heirs of Corazon Villeza v. Aliangan, Petitioners Imelda V. dela Cruz I, Stella Imelda II Villeza, Imelda Villeza III, Robyl O. Villeza, and Abigail Wehr are the collateral heirs of the late Corazon Villeza, who died intestate on August 3, 2009 in Angadanan, Isabela. Respondents Elizabeth S. Aliangan and Rosalina S. Aliangan, represented by Roger A. Banang, alleged that Corazon sold to them three parcels of land in Angadanan: (1) a 540.5 sqm residential lot with improvements at Centro I under Transfer Certificate of Title (TCT) No. T-356999 by a Deed of Conditional Sale dated January 10, 2006 for ₱450,000; (2) a 36,834 sqm agricultural lot at Barangay Bunay under TCT No. T-297393 by an oral contract in 2005 for ₱250,000; and (3) a 225 sqm lot with house at Poblacion under TCT No. T-106311 by an oral contract in 2000 for ₱307,020.52. Respondents sent remittances, secured acknowledgment receipts from Corazon, and alleged full payment before her death. When the heirs refused toCase Digest (G.R. No. 244667-69)
Facts:
- Parties and properties involved
- Petitioners: Heirs of Corazon Villeza (Imelda V. dela Cruz, Stella Imelda II Villeza, Imelda Villeza III, Robyll O. Villeza, Abigail Wehr) and other heirs of Rosario Agpaoa.
- Respondents: Elizabeth S. Aliangan and Rosalina S. Aliangan as buyers of three parcels of land in Angadanan, Isabela.
- Transactions and conflicts
- Centro I property (540.5 sq.m.)
- Deed of Conditional Sale (DCS) dated January 10, 2006 between sellers Corazon and Rosario, buyers Elizabeth and Rosalina; purchase price ₱450,000 with ₱50,000 down payment and ₱10,000 monthly installments.
- Respondents remitted a total of ₱454,233 by April 2008; sellers died on August 3 and September 1, 2009 without executing Deeds of Absolute Sale (DAS); petitioners later discovered allegedly forged absolute-sale contracts and repudiated the DCS.
- Bunay property (36,834 sq.m.)
- Oral sale in 2005 by Corazon to Elizabeth for ₱250,000; two remittances of ₱125,000 each; no conveyance upon Corazon’s death.
- Petitioners denied existence of any contract; remittance receipts deemed self-serving.
- Poblacion property (225 sq.m.)
- Oral sale from 2000 to 2003 by Corazon to Rosalina; remittances totalling ₱307,020.52; Acknowledgment Receipt of ₱85,000 on February 11, 2005 as full payment.
- No transfer at death; petitioners disputed the authenticity of the oral sale.
- Procedural history
- RTC (Branch 20, Cauayan City) consolidated the three cases, rendered separate Decisions (August 30, 2016) granting specific performance, ordering execution of deeds, awarding moral (₱100,000), exemplary (₱50,000) damages, and attorney’s fees (₱150,000).
- CA (First Division) Decision (December 17, 2018) denied petitioners’ appeals, affirmed RTC with deletion of moral and exemplary damages, maintained attorney’s fees and costs.
- Supreme Court: Petition for Review under Rule 45 filed by petitioners; respondents filed Comment; petitioners filed Reply.
Issues:
- Whether the CA erred in ruling there is a perfected agreement of sale between respondents and Corazon.
- Whether the CA erred in not dismissing the cases for specific performance for lack of cause of action because respondents should have filed against Corazon’s estate under probate rules (Rules 86, 87; Rule 89).
- Whether the CA erred in affirming the RTC ordering petitioners to execute deeds of conveyance in favor of respondents.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)