Title
Papa vs. A.U. Valencia and Co., Inc.
Case
G.R. No. 105188
Decision Date
Jan 23, 1998
A

Case Digest (G.R. No. 105188)

Facts:

  • Background of the Transaction
    • On June 15, 1973, Angela M. Butte, through her attorney-in-fact Myron C. Papa, purportedly sold to Félix PeAarroyo, through A.U. Valencia & Co., Inc., a 286.60 sqm parcel in La Loma, Quezon City, under TCT No. 28993, for a total of ₱45,000 (₱5,000 cash on May 24, 1973, and ₱40,000 by check on June 15, 1973).
    • Prior to the sale, the property was mortgaged to Associated Banking Corporation; title release was withheld pending redemption of several mortgaged parcels. Butte died before title issuance; PeAarroyo annotated an adverse claim on January 18, 1977.
  • Procedural History
    • June 1982: Valencia and PeAarroyo filed in RTC Pasig a complaint for specific performance against Papa (as Butte’s administrator), seeking delivery of the owner’s duplicate of TCT No. 28993, accrued and future rentals (₱800/mo.), attorney’s fees (₱20,000), and costs.
    • Intervention and Third-Party Practice:
      • Delfin Jao intervened, claiming subsequent purchase rights from PeAarroyo (Aug 20, 1973) and damages for non-delivery.
      • Papa filed a third-party complaint against spouses Reyes & Santos, who acquired the lot at a 1980 tax sale for ₱14,000, alleging invalidity and seeking cancellation of the tax sale.
    • June 29, 1987: RTC rendered judgment granting Papa redemption rights, ordering conveyance to PeAarroyo or payment of ₱45,000 + 12% interest, requiring PeAarroyo to convey to Jao or pay ₱5,000 + 12% interest, and awarding ₱5,000 attorney’s fees.
    • January 27, 1992: CA affirmed with modification—ordering Papa to deliver the owner’s duplicate of TCT No. 28993 (or effect issuance of a new title in PeAarroyo’s name); affirmed remaining RTC relief; costs against Papa.
    • April 22, 1992: CA denied Papa’s motion for reconsideration.
    • January 23, 1998: SC docketed Papa’s Rule 45 petition for review on certiorari, raising issues on consummation of sale, non-joinder of estates, and cancellation of assignment.

Issues:

  • Whether the sale was consummated despite Papa’s alleged non-encashment of the ₱40,000 check.
  • Whether the CA erred by, in effect, nullifying or ignoring an alleged mortgage-rights assignment in favor of the Estate of Ramon Papa, Jr., a non-party.
  • Whether the Estates of Angela M. Butte and Ramon Papa, Jr. were indispensable parties whose absence vitiates the proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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