G.R. No. 140758 - People vs. Geron

Melinda Malabanan (Melinda), widow of Jose Malabanan (Jose), and Jose acquired a 310-square meter portion of a 2,000-square meter land registered under Maria Cristina Rodriguez via a Deed of Absolute Sale dated December 18, 1984.
On February 21, 1985, Transfer Certificate of Title (TCT) No. T-188590 was issued in the names of "Jose, married to Melinda," covering the disputed property.
The spouses built a family home on the property with possession since 1984.

Melinda went to work abroad in Libya on October 13, 1984.
Jose was murdered on June 12, 1985; Melinda temporarily returned to the Philippines between June 25 and August 19, 1985, then returned to Libya until November 8, 1990.

Melinda later discovered that TCT No. T-188590 was cancelled and the property registered under Spouses Dominador III and Guia Montano (Montano Spouses).
The following transactions took place:

March 20, 1985: Special Power of Attorney (SPA) allegedly executed by Jose, authorizing Francisco Malabanan, Jr. (father-in-law) to mortgage, lease, or sell the property.
May 29, 1985: Francisco sold the property to Benjamin M. Lopez (his brother-in-law), leading to cancellation of TCT No. T-188590 and issuance of TCT No. T-195283 in Lopez’s name on July 18, 1985.
September 9, 1985: Francisco bought back the property from Lopez; TCT No. T-195283 was cancelled and TCT No. T-198039 issued under Francisco’s name on September 18, 1985.

Upon the death of Melinda’s mother-in-law Adelfina Mendoza, an Extrajudicial Settlement adjudicated the property (under TCT No. T-198039) to Ramon Malabanan, Jose’s brother.
Ramon sold the property to the Montano Spouses on June 17, 1994, who obtained TCT No. T-467540.

June 1, 1994: Melinda filed a Complaint for Annulment of Title with Damages against Ramon and Prescila Malabanan, and Francisco Malabanan.
Melinda filed an Amended Complaint to include the Montano Spouses, alleging forgery of her signature in the SPA and continued ownership.
Respondents counterclaimed that the property was an advance on Jose’s legitime, paid for by Francisco, who also paid for house construction; they alleged Melinda consented to Francisco reacquiring the property.
Dominador Montano testified he was not aware of Melinda’s claim before buying the property and offered compensation after discovering tax declaration in Melinda’s name.

The Regional Trial Court (RTC) ruled in favor of Melinda, nullifying the SPA, subsequent transactions, and Extrajudicial Settlement, and ordered reinstatement of TCT No. T-188590 in Melinda’s name.
The Court of Appeals (CA) reversed the RTC, holding the property was Jose’s exclusive property and the transactions valid, emphasizing the presumption of gift in favor of a child when parents pay for a property but title is in the child’s name.
CA ruled Melinda’s forged signature in the SPA did not invalidate Jose’s authority to grant the SPA.
Melinda’s Motion for Reconsideration was denied.

Melinda filed a Petition for Review on Certiorari before the Supreme Court.
Respondents failed to comment; the Court resolved to dispense with their Comment.
The issue before the Supreme Court was whether the property was conjugal and if its sale without the wife’s consent was void.

Whether the disputed property formerly covered by TCT No. T-188590 was conjugal property of Melinda and Jose.
Whether the sale and subsequent transfer of the property without Melinda’s consent were valid.
Whether the Special Power of Attorney authorizing the sale was valid considering the alleged forgery of Melinda’s signature.
Whether the Montano Spouses were buyers in good faith.
Whether the annulment of titles and orders of damages awarded by the RTC should be reinstated.