Case Digest (G.R. No. L-14524)
Facts:
Felix Molina v. Court of Appeals and Basilisa Manjon, G.R. No. L-14524, October 24, 1960, the Supreme Court En Banc, Reyes, J., writing for the Court.Plaintiff Basilisa Manjon filed Civil Case No. 2796 in the Court of First Instance of Camarines Sur seeking recovery of possession and declaration of ownership over a parcel of land; defendant Felix Molina answered, denied the material averments and filed a counterclaim alleging that Manjon sold the parcel to him around 1938 (formalized by a notarial deed in 1943) and that he had been in continuous possession since 1938, praying that Manjon's complaint be dismissed and defendant's title declared valid.
Manjon denied the due execution of the alleged sale and testified that the instrument was a fictitious, simulated sale executed in 1943 at Molina’s suggestion to protect her from guerilla investigation; she produced a contemporaneous statement (Exhibit D) in which Molina allegedly admitted the simulation. Molina denied signing Exhibit D and offered specimens of his genuine signature for comparison (Exhs. 6–15). At trial the judge summarized the evidence but declined to determine whether the sale was simulated; instead the trial court declared Manjon the lawful owner on the ground that she could not have validly disposed of the land in 1938 or 1943 because the land remained part of the public domain and Manjon received a sales patent only on June 4, 1948.
Molina appealed to the Court of Appeals assigning, among other errors, the trial court’s failure to rule on whether the sale was simulated. The Court of Appeals affirmed the trial court, accepting its reasoning and likewise declining to make a definitive finding on simul...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the lower court’s judgment without resolving whether the alleged 1938/1943 sale was simulated?
- If the sale was genuine, would a subsequently acquired title in the seller (Manjon) pass to the buyer (Molina) by...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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