Title
Reyes vs. Zubiri
Case
G.R. No. 62773
Decision Date
May 8, 1992
The Supreme Court ordered Zubiri to return the property to the petitioners, ruling him a creditor and guilty of falsifying public documents.
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Case Digest (G.R. No. 62773)

Facts:

  • Petitioners: Olimpio Reyes, Antonio G. Reyes, Irene R. Reyes, Petronila R. Carreon, Natividad R. Gahol, Florencio Carreon, Dioscoro Gahol.
  • Respondents: Oscar R. Zubiri, Eufracia Gabay, Court of Appeals.
  • On August 31, 1959, Olimpio Reyes and Eulogia Gutierrez leased a 4,022 square meter land in Barrio Panghulo, Malabon, Rizal to "Capiz and Rafael" for ten years.
  • Lease agreement stated that improvements made by the lessee would belong to the lessor if not removed within sixty days after lease expiration.
  • Improvements included an adobe stone fence, garage, factory, two-storey residential building, and canteen, all registered.
  • On October 10, 1961, Cecilio M. Rafael assigned his lease rights to Republic Bank, which was registered.
  • In 1967, Rafael assigned his rights to Atty. Oscar S. Zubiri as payment for legal services, but this assignment was not registered.
  • After Rafael defaulted, Republic Bank chose not to auction the property.
  • Following Eulogia Gutierrez's death, the other petitioners substituted her in the case.
  • Dispute arose when Zubiri allegedly deceived Olimpio Reyes into signing documents that sold the improvements to him.
  • Petitioners filed a suit against Zubiri for annulment of contracts, recovery of ownership, and damages.
  • Trial court ruled in favor of petitioners, declaring documents null and void and affirming their ownership.
  • Court of Appeals reversed the trial court's decision, prompting the petition for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the Court of Appeals' decision and reinstated the trial court's ruling, except for th...(Unlock)

Ratio:

  • The Supreme Court determined that the Court of Appeals incorrectly concluded that Atty. Zubiri had rights to the improvements based on an unregistered assignment from Rafael.
  • The registered assignment to Republic Bank meant Zubiri could not claim rights to the improvements since Rafael had already assigned his leasehold rights to the bank.
  • Zubiri, as Rafael's attorney, was prohibited from acquiring rights ...continue reading

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