Case Digest (G.R. No. 140228) Core Legal Reasoning Model
Facts:
This case involves multiple petitioners, all grandchildren of Pedro Medina from two separate marriages, and the respondent, Greenfield Development Corporation. Pedro Medina, his brother Alberto Medina, and Alberto’s daughter Nazaria Cruz executed a Contract to Sell in favor of Greenfield Development Corporation on June 5, 1962, covering a 17,121-square-meter parcel of land in Muntinlupa City covered by TCT No. 100177 (Lot 90-A). Subsequently, a Deed of Sale was executed on June 27, 1962, signed by various Medina family members and Nazaria Cruz as vendors, and another Deed of Absolute Sale with Mortgage was executed on September 4, 1964, in favor of Greenfield Development Corporation for another parcel (Lot 90-B) covered by TCT No. 100178, measuring 16,291 square meters. These sales led to Greenfield registering title over these lots, which were later consolidated and registered under TCT Nos. 202295, 202296, and 202297 in 1995.
On November 6, 1998, the petitioners filed Civil C
Case Digest (G.R. No. 140228) Expanded Legal Reasoning Model
Facts:
- Parties and lineage
- Petitioners are grandchildren of Pedro Medina from two marriages: first to Isadora San Jose (children: Rafael, Rita, and Remegia) and second to Natalia Mullet (children: Cornelio, Brigida, Balbino, Crisanta, Rosila). Except for Balbino and Crisanta, all children of Pedro had their own children, who constitute the petitioners.
- Other parties include the heirs of Nazaria Cruz, Alberto Medina’s daughter, who joined as unwilling co-plaintiffs.
- Transactions involving the subject properties
- On June 5, 1962, Pedro Medina, Alberto Medina, and Nazaria Cruz executed a notarized Contract to Sell in favor of respondent Greenfield Development Corporation over Lot 90-A (TCT No. 100177), measuring 17,121 square meters.
- On June 27, 1962, a notarized Deed of Sale was executed in favor of respondent, signed by various Medinas and Cruz as vendors, covering Lot 90-A.
- On September 4, 1964, a notarized Deed of Absolute Sale with Mortgage was executed involving Lot 90-B (TCT No. 100178), measuring 16,291 square meters, with the same signatories.
- Respondent registered titles over these lots under TCT Nos. 100578 and 133444, which were later consolidated as TCT Nos. 202295, 202296, and 202297 (registered on July 19, 1995).
- Judicial proceedings
- On November 6, 1998, petitioners filed Civil Case No. 98-233 for annulment of titles and deeds, reconveyance, damages with preliminary injunction and restraining order against the respondent and the Register of Deeds of Makati.
- Petitioners alleged they are co-owners of the properties, claiming the deeds and signatures in the sale are simulated, and the respondent is not the lawful owner despite the transfer of titles.
- Petitioners remained in possession and had their caretaker, Santos Arevalo, residing in the property. They annotated an adverse claim on the titles on July 13, 1998.
- After the annotation, respondent fenced the property and barred petitioners’ access, prompting their request for a temporary restraining order and writ of preliminary injunction.
- Respondent denied petitioners' allegations, claiming ownership supported by notarized contracts and registered titles; it also denied that Arevalo was petitioners’ caretaker, asserting that Arevalo was employed by respondent.
- Trial court and Court of Appeals rulings
- On January 18, 1999, the Regional Trial Court (RTC), Muntinlupa City, granted the writ of preliminary injunction, enjoining the respondent and its agents from preventing petitioners and caretaker from entering the property upon posting a bond of ₱100,000.
- Respondent filed a special civil action for certiorari and prohibition with the Court of Appeals (CA).
- On July 16, 1999, the CA nullified the RTC’s issuance of the writ, holding that the RTC gravely abused its discretion by issuing the injunction without substantial evidence, relying excessively on petitioners’ allegations.
- CA ruled the deeds had the presumption of validity, the titles were indefeasible, the respondent was in constructive possession, and that petitioners’ action was already barred by prescription.
- Petitioners sought relief from the Supreme Court (SC), assailing CA’s decision on various grounds including the lack of evidentiary support, the validity of respondent’s transfer certificates, and the propriety of presumption of regularity.
Issues:
- Whether the trial court erred in issuing the writ of preliminary injunction granting petitioners’ prayer for injunctive relief against respondent.
- Whether the Court of Appeals erred in nullifying the writ of preliminary injunction.
- Whether the presumption of validity of notarized documents and Torrens titles applies in the circumstances of this case.
- Whether petitioners’ right to impugn respondent’s titles had prescribed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)