Title
Nazareno vs. Court of Appeals
Case
G.R. No. 138842
Decision Date
Oct 18, 2000
Dispute over simulated property sales between heirs of Maximino Nazareno, Sr.; Supreme Court nullified deeds, restoring properties to estate due to lack of consideration and tax evasion.
A

Case Digest (G.R. No. 138842)

Facts:

Natividad P. Nazareno and Maximino P. Nazareno, Jr., petitioners, sought review of the decision of the Court of Appeals in a dispute over several real properties located in Quezon City and proceedings that originated in Naic, Cavite; the Supreme Court rendered its decision on October 18, 2000. The dispute arose from a Deed of Absolute Sale dated January 29, 1970, whereby the deceased spouses Maximino A. Nazareno, Sr. and Aurea Poblete purportedly sold six Quezon City lots to their daughter Natividad for P47,800.00 and P4,800.00, and from a later sale on July 31, 1982 of Lot 3-B to Maximino, Jr., which resulted in the issuance of several Transfer Certificates of Title in the name of Natividad and later of Maximino, Jr. Following the deaths of Aurea in 1970 and Maximino, Sr. in 1980, Romeo P. Nazareno was appointed administrator of the estate of Maximino, Sr. in intestate proceedings (Sp. Proc. No. NC-28), and he discovered the 1970 deed; Romeo alleged that the purported sales were simulated and without consideration and therefore void. Maximino, Jr. filed and won a separate action for recovery of possession of Lot 3-B against Romeo and Eliza, which resulted in TCT No. 293701 issued to Maximino, Jr., but Romeo thereafter filed on June 15, 1988 an action for annulment of sale with damages against Natividad and Maximino, Jr. in the Regional Trial Court of Quezon City (Civil Case No. 88-58), alleging lack of consideration; Natividad and Maximino, Jr. filed a third-party complaint concerning Lot 3. The trial court declared the deeds null in an August 10, 1992 judgment later modified on October 14, 1992, and the Court of Appeals on May 29, 1998 further modified the trial court’s disposition by declaring the January 29, 1970 and July 31, 1982 deeds null and void, ordering that, except for Lots 13 and 14 which had passed to third persons, Lots 3, 3-B, 10 and 11 form part of the estate of Maximino Nazareno, Sr., and directing the Register of Deeds to restore specified titles; petitioners’ motion for reconsideration to the Court of Appeals was denied on May 27, 1999, prompting this petition for review.

Issues:

Can the uncorroborated testimony of Romeo P. Nazareno overcome the presumption of validity afforded a notarized deed of sale? Is the Deed of Absolute Sale dated January 29, 1970 valid in light of other notarized dispositions executed by the deceased spouses and related extrinsic evidence? Is the said deed an indivisible contract such that the estate of Maximino A. Nazareno, Sr. alone cannot seek its annulment absent participation of Aurea’s estate? Should the titles issued to third persons and to Maximino, Jr. be cancelled and restored pursuant to the January 29, 1970 deed and related transfers? Does an implied trust and the duty of collation under the Civil Code apply to the properties conveyed to Natividad?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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