Title
Loyola vs. Court of Appeals
Case
G.R. No. 115734
Decision Date
Feb 23, 2000
Disputed land sale by 94-year-old Gaudencia Zarraga contested over validity, fraud, and price inadequacy; Supreme Court upheld sale as legitimate.

Case Digest (G.R. No. 115734)

Facts:

Ruben Loyola, Candelaria Loyola, Lorenzo Loyola, Flora Loyola, Nicandro Loyola, Rosario Loyola, Teresita Loyola and Vicente Loyola v. The Honorable Court of Appeals, Nieves, Romana, Romualdo, Guillermo, Lucia, Purificacion, Angeles, Roberto, Estrella, All Surnamed Zarraga and the Heirs of Jose Zarraga, namely Aurora, Marita, Jose, Ronaldo, Victor, Lauriano, and Ariel, all surnamed Zarraga, G.R. No. 115734, February 23, 2000, Second Division, Quisumbing, J., writing for the Court.

The petitioners (subsisting plaintiffs in the trial court proceedings) are succession/substitute plaintiffs who sought annulment of a deed of sale and cancellation of the corresponding Transfer Certificate of Title covering a parcel described as Lot 115-A-1 (753 sq. meters) in Poblacion, Binan, Laguna. Private respondents are various members of the Zarraga family who claim title under a deed dated August 24, 1980 and TCT No. T-116067 issued in their favor.

The property was originally co-owned by siblings Mariano and Gaudencia Zarraga. Mariano predeceased Gaudencia; Gaudencia died single and childless on August 5, 1983. Prior litigation (Civil Case No. B-1094 in the Court of First Instance of Laguna, Branch 1) eventually adjudicated Gaudencia the owner of one-half of the parcel; Romualdo (one of the private respondents) lost his challenge when this Court denied his petition (G.R. No. 59529) on March 17, 1982. While G.R. No. 59529 was still pending before this Court, Gaudencia purportedly executed on August 24, 1980 a notarized instrument denominated "Bilihan Tuluyan ng Kalahati (1/2) ng Isang Lagay na Lupa" selling her half-share for P34,000 to several vendees including some private respondents.

After the CFI decision in B-1094 became final, private respondents moved for execution; a sheriff's deed of reconveyance to Gaudencia was executed on February 16, 1984. Despite that, the Register of Deeds (Calamba Branch) issued TCT No. T-116067 in favor of private respondents on July 23, 1984 based on the 1980 sale. On January 31, 1985, Victorina and Cecilia (sisters of Gaudencia and original plaintiffs in RTC Civil Case No. B-2194) filed a complaint in the Regional Trial Court of Binan, Laguna (Branch 24) to annul the sale and the title; the RTC rendered judgment in favor of plaintiffs, declaring the deed simulated and the TCT void ab initio, and ordering cancellation and reconveyance.

Private respondents appealed to the Court of Appeals (CA-G.R. No. CV 36090). On August 31, 1993 the Court of Appeals reversed the RTC: it dismissed the plaintiffs’ complaint and declared the 1980 deed and TCT lawful, valid and effective. The original plaintiffs Victorina and Cecilia died while the case was pending and were substituted by the current petitioners; petitioners filed a motion for reconsideration on September 15, 1993 which ...(Pro-only)

Issues:

  • Is the deed of absolute sale dated August 24, 1980 (and the corresponding Transfer Certificate of Title) valid...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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