Case Digest (G.R. No. 199180)
Facts:
Thelma Rodriguez v. Spouses Jaime Sioson and Armi Sioson, G.R. No. 199180, July 27, 2016, Supreme Court Third Division, Reyes, J., writing for the Court. Before the Court is a petition for review under Rule 45 challenging the Court of Appeals' Decision dated May 26, 2011 and its Resolution dated October 21, 2011 in CA‑G.R. CV No. 94867.
The dispute arises from successive transactions over a portion of former Lot 398 (22,398 sq.m.), originally titled in the name of Neri delos Reyes, married to Violeta Lacuata (mother title TCT No. T‑86275). Around 1997 the Municipality of Orani purchased about 1.7 ha of Lot 398; the mother title was to be surrendered for subdivision, with Neri to share expenses. Lot 398 was subdivided into Lots 398‑A to 398‑E; Lots 398‑A and 398‑B remained registered to Neri (TCT Nos. T‑209894 and T‑209895), but the owner's duplicates were retained by the Municipality pending Neri's payment of subdivision expenses.
At the suggestion of the then‑mayor, Neri allegedly agreed to sell Lot 398‑A to his aunt, Thelma Rodriguez, for P1,243,000.00. On March 20, 1997 Thelma issued a check which was not fully honored; she ultimately paid only P442,293.50 in installments. In November 2001 Thelma annotated an adverse claim on TCT No. T‑209894 and later filed Civil Case No. 7394 for injunction claiming ownership, attaching an undated, unnotarized deed of absolute sale allegedly in her favor.
In May 2002 Neri executed an affidavit of loss of the owner's copies of TCT Nos. T‑209894 and T‑209895 and caused reconstitution copies to be issued. He also caused cancellation of Thelma's adverse claim. On November 27, 2002 Neri executed a deed of sale conveying Lot 398‑A to the respondents (Spouses Sioson, spouses Camacho, and Agnes Samonte), and TCT No. T‑226775 issued in their names. The respondents declared and paid taxes on the lot and attempted physical possession; Thelma obstructed their entry and the respondents filed a forcible entry ejectment case (Civil Case No. 843), still pending.
Upon learning of the second sale, Thelma filed Civil Case No. 7664 (Declaration of Nullity of Second Sale and TCT No. T‑226775) on February 11, 2003, proffering a dated, notarized deed of sale (April 10, 1997) signed by both her and Neri. The respondents answered that they were innocent purchasers for value, bought after cancellation of Thelma's adverse claim, and filed an intervention in Civil Case No. 7394.
The Regional Trial Court (RTC), Branch 3, Bataan, consolidated Civil Cases Nos. 7394 and 7664 and, by Joint Decision dated August 13, 2009, ruled for Thelma: it declared the second deed of sale and TCT No. T‑226775 null and void, ordered reinstatement of TCT No. T‑209894 in Neri's name, and granted permanent injunction in Civil Case No. 7394. The RTC found an executed sale to Thelma (consideration P1,243,000; partial payment acknowledged P442,293.50) and concluded a double sale occurred.
The respondents moved for reconsideration, denied by RTC Order dated January 13, 2010, and appealed to the Court of Appeals (CA). The CA, in its Decision dated May 26, 2011, reversed the RTC: it held the agreement between Neri and Thelma was a mere contract to sell (ownership was conditioned on full payment), therefore the sale to the respondents and issuance of TCT No. T‑226775 were declared valid; the CA dismissed the complaints. The CA denied Thelma's motion for reconsideration in its October 21, 2011 Res...(Subscriber-Only)
Issues:
- Whether the transaction between Neri delos Reyes and Thelma Rodriguez is a contract of sale or a contract to sell.
- If the transaction were a sale, whether the absence of the wife's (Violeta's) consent renders the sale void as to conjugal property.
- Whether the respondents are buyers in good faith and whether TCT No. T‑226775 must be declared valid (i.e., whether registrati...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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