Case Digest (G.R. No. 150913)
Facts:
In Spouses Teofilo and Simeona Rayos, and George Rayos v. Donato Reyes et al., the petitioners are the spouse-owners Teofilo and Simeona Rayos and George Rayos, and the respondents are Donato, Saturnino, Tomasa R. Bustamante, and Toribia R. Camelo, heirs of Mamerto Reyes. The controversy involves three unregistered parcels totaling approximately 130,947 square meters in Brgy. Sapa, Burgos, Pangasinan. On September 1, 1957, Francisco and Asuncion Tazal sold these parcels to Mamerto Reyes for ₱724.00, granting themselves a right to repurchase within two years by reimbursing the purchase price and all reconveyance expenses. Reyes took possession and paid taxes. Before the two-year period expired, however, Tazal sold two parcels to Blas Rayos on December 24, 1958, and the third parcel to the petitioners on June 22, 1961; Blas Rayos thereafter sold his two lots to the petitioners on July 1, 1961. Meanwhile, on May 9, 1960, Francisco Tazal filed Civil Case No. A-245 in the Court of Fi...Case Digest (G.R. No. 150913)
Facts:
- Original sale and right to repurchase
- Three parcels of unregistered land (approx. 130,947 sqm) in Brgy. Sapa, Burgos, Pangasinan, owned by spouses Francisco and Asuncion Tazal.
- 1 September 1957: Tazals sold to Mamerto Reyes for ₱724.00, with right to repurchase within two years by paying purchase price plus expenses. Reyes took possession and paid taxes thereafter.
- Intermediate transactions and redemption attempt
- 24 December 1958: Tazal sold two parcels to Blas Rayos for ₱420.00 without exercising his repurchase right.
- 1 September 1959: Two-year redemption period expired unexercised. Tazal attempted to repurchase by treating the 1957 sale as equitable mortgage and tendering ₱724.00; Reyes refused.
- Civil Case No. A-245 (declaration of equitable mortgage)
- 9 May 1960: Tazal filed CFI Pangasinan Civil Case No. A-245 seeking declaration of 1957 deed as equitable mortgage, acceptance of tendered payment, cancellation of mortgage and reconveyance.
- 26 September 1962: Parties stipulated to facts—genuine deed, deposit of ₱724.00, and taxes paid by Reyes from 1958 to 1962.
- Decisions in Civil Case No. A-245
- 5 January 1963: Trial court ruled the 1957 transaction a true sale with right to repurchase (not mortgage), and allowed repurchase within 30 days from finality by paying ₱724.00 plus contractual and necessary expenses (Art. 1616).
- Reyes appealed to the Court of Appeals; case elevated to the Supreme Court. Judgment became final on 20 June 1990.
- Acquisition by petitioners and Civil Case No. A-2032
- While A-245 was pending, petitioners acquired two parcels from Blas Rayos (1 July 1961) and the third from Tazal (22 June 1961).
- Petitioners did not repurchase within 30 days after finality; they believed the ₱724.00 deposit sufficed.
- 6 July 1992: Reyes heirs executed affidavit of adjudication, declared properties, and on 19 January 1993 registered the 1957 sale.
- 8 July 1993: Reyes heirs filed CFI Civil Case No. A-2032 for damages and recovery of ownership and possession.
- Decisions in Civil Case No. A-2032 and on appeal
- 15 November 1996: RTC Alaminos rendered decision voiding the Tazal and Rayos deeds of sale, decreeing ownership in Reyes heirs, and awarding damages (litigation expenses ₱20,000; attorney’s fees ₱10,000; exemplary ₱50,000).
- 31 May 2001: Court of Appeals affirmed in toto—held the ₱724.00 deposit belated and incomplete, estoppel and laches inapplicable, and petitioners not in good faith.
Issues:
- Does the deposit of ₱724.00 in Civil Case No. A-245 constitute valid consignation effecting redemption within the legal period?
- Are respondents barred by estoppel or laches from asserting ownership and recovery in Civil Case No. A-2032?
- Are petitioners purchasers in good faith and for value of the unregistered parcels, and thus protected against prior claims (Art. 1544 Civil Code)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)