Title
Mapalo vs. Mapalo
Case
G.R. No. L-21489
Decision Date
May 19, 1966
Spouses deceived into fraudulent land sale; Supreme Court ruled 1936 deed void due to lack of consideration, upheld ownership of western portion.
A

Case Digest (G.R. No. L-21489)

Facts:

  • Background of Parties and Property
    • Petitioners Miguel Mapalo and Candida Quiba are simple, illiterate farmers and registered owners (O.C.T. No. 46503) of a 1,635-sq.m. residential lot in Manaoag, Pangasinan.
    • Out of affection for Miguel’s brother Maximo, they intended to donate the eastern half of the lot to him; the original title was delivered in anticipation of this donation.
  • Fraudulent Deed of Sale of October 15, 1936
    • Maximo and the notary public “translated” a deed of absolute sale covering the entire lot, representing it to the spouses as a donation of the eastern half.
    • The sale document recited a P500 consideration, which the spouses never received; their signatures were procured by fraud.
    • Immediately thereafter, the spouses erected a permanent fence bisecting the lot and continued uninterrupted possession of the western half.
  • Subsequent Registrations and Litigation
    • On March 15, 1938, Maximo registered the deed of sale and secured TCT No. 12829 in his name covering the entire property.
    • On October 20, 1951, Maximo sold the entire lot to Evaristo, Petronila, Pacifico and Miguel Narciso for P2,500; the Narcisos registered their purchase on November 5, 1951 (TCT No. 11350) and occupied only the eastern half.
    • February 7, 1952: Narcisos sued the Mapalo spouses (CI No. 11991) for declaration of ownership of the entire lot, possession of the western half, damages and rentals; the spouses counterclaimed for cancellation of title as to the western half and reconveyance.
    • December 16, 1957: The Mapalo spouses filed a separate suit (CI No. U-133) to annul both the 1936 and 1951 deeds insofar as they affected the western half.
    • January 18, 1961: The Court of First Instance, Urdaneta, rendered judgment (a) dismissing Narcisos’ complaint; (b) treating the 1936 deed as a valid donation only of the eastern half and null as to the western half; (c) ordering subdivision of the lot; and (d) directing issuance of separate titles—one for the spouses’ western half and one for the Narcisos’ eastern half.
    • May 28, 1963: The Court of Appeals reversed solely on prescription grounds, holding that the spouses’ action to annul the 1936 deed as voidable had prescribed four years from its registration in 1938.

Issues:

  • Whether the October 15, 1936 deed of sale is void ab initio (inexistent) or merely voidable as to the western half of the lot.
  • Whether the action to annul the 1936 deed has prescribed.
  • Whether the Narcisos are purchasers in good faith and for value with respect to the western half.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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