Case Digest (G.R. No. 140848)
Facts:
Ramon Ramos v. Heirs of Honorio Ramos Sr., G.R. No. 140848, April 25, 2002, Supreme Court Third Division, Panganiban, J., writing for the Court.Petitioner Ramon Ramos (the vendee) is sued by respondents, the heirs of Honorio Ramos Sr. — Pureza N. Ramos, Honorio Ramos Jr., and Gwendolyn Ramos‑Garcia — who asserted a co‑ownership interest in Lot No. 2961, Macasandig, Cagayan de Oro City. The dispute centers on a Deed of Absolute Sale dated January 11, 1954, in which Salud Abejuela purportedly sold Lot 2961 to Ramon for P1,000.
Background facts: Lucio Ramos and Salud Abejuela were spouses and parents of Juan, Honorio, Josefa and Ramon. Salud died in 1966 and Lucio in 1974. The children executed an extrajudicial settlement in September 1972. In March 1975 Juan and Josefa filed Civil Case No. 4667 (partition and annulment of confirmatory deeds) against Ramon and Honorio; the parties submitted a compromise on November 10, 1975 that waived Juan and Josefa’s claims over Lot 2961 among other parcels.
In July 1991 the respondents (as heirs of Honorio) filed a suit in the Regional Trial Court (RTC) of Cagayan de Oro for conveyance of title and partition of Lot 2961, alleging the 1954 sale was simulated — a device to enable Ramon to use the land as collateral — and that Honorio was a co‑owner entitled to one‑half. The RTC (Judge Leonard M. Demecillo) dismissed the complaint in a May 6, 1994 decision, finding simulation unproven (no contra documento, hearsay excluded, petitioner’s acts of dominion, and estoppel/laches). The Court of Appeals (CA) reversed on October 26, 1999 (CA‑GR CV No. 46938), finding badges of simulation (family relationship between vendor and vendee, low consideration, impleading of Honorio in the 1975 case, Pureza’s written demand for partition, and prescription not yet running) and ordered partition of Lot 2961 into two equal parts with Ramon to convey one half to respondents as Honorio’s heirs.
Petitioner sought review by the Supreme Court by a Petition for Review on Certiorari (Rule 45), contending the 1954 Deed was a valid sale and that respondents failed to overcome ...(Subscriber-Only)
Issues:
- Was the January 11, 1954 Deed of Absolute Sale a real and genuine sale conveying ownership to Ramon Ramos?
- Did respondents present strong and convincing evidence sufficient to overcome the presumption of regularity of the notarized Deed of Sale?
- If respondents’ claim had merit, was it already barred by prescription?
- If respondents’ claim had merit, was it unenforce...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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