Case Digest (G.R. No. 173425) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The controversy involves a 12.3-hectare parcel in Magdum, Tagum City, originally titled in the name of the late Dominador Ramones and covered by Original Certificate of Title No. (P-1324) P-232. In 1960 Dominador executed a Contract of Sale in favor of Bias Mejia, father of respondent Nestor C. Mejia, for six hectares, while the remaining 6.3 hectares was sold to Pablo Benitez in 1965. Title remained in the spouses Ramones. After Bias’s death, his son Nestor occupied the entire tract and retained the two ancient sale instruments. In 2005 Nestor met Renato Padillo, President of Royal Plains View, Inc. (“petitioner Corporation”), and they partitioned the property, resulting in Transfer Certificates of Title Nos. T-225549 and T-225550, both still in the spouses Ramones. On March 23, 2005, and again on April 11, 2007, Nestor and the Corporation executed Deeds of Conditional Sale over TCT No. T-225549 for ₱8,000,000, with substantial down and installment payments. They also agreed ve Case Digest (G.R. No. 173425) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Subject Property and Original Transactions
- Lot No. 371, original area 123,099 sqm, covered by OCT No. (P-1324) P-232 in Tagum City, owned by Dominador Ramones.
- September 17, 1960: Dominador executed Contract of Sale in favor of Bias Mejia for 7,309 sqm (reduced by agreement to 6 ha); title remained in Dominador’s name.
- February 17, 1965: Dominador sold remaining 6.3 ha to Pablo Benitez by Deed of Absolute Sale.
- Chain of Possession and Splitting of Title
- Bias died; his son Nestor C. Mejia inherited his rights and occupied the entire 12.3 ha under OCT P-232.
- 2005: Nestor met Renato Padillo of Royal Plains View, Inc. (RPVI). They agreed to split the 12.3 ha into two titles, resulting in TCT Nos. T-225549 and T-225550, both still in spouses Ramones’ names. RPVI retained T-225549; T-225550 delivered to Casimiro Benitez.
- Deeds of Conditional Sale and Alleged Default
- March 23, 2005: RPVI (through Rosemarie Padillo) and Nestor entered into a Deed of Conditional Sale of TCT No. T-225549 for ₱8 million (₱500,000 down, 36 monthly installments).
- April 11, 2007: They revoked the 2005 deed and executed a new Deed of Conditional Sale reflecting ₱1,972,000 paid and 40 monthly installments of ₱150,000, plus an alleged oral agreement to divide the 60,000 sqm into two halves.
- RPVI sold individual lots to third parties; Nestor allegedly sold the whole property to spouses Egina for ₱12 million; eight derivative TCTs issued then later cancelled.
- Rescission and Litigious History
- RPVI defaulted on installments; Nestor issued a notarized “Rescission of Deed of Conditional Sale” dated February 5, 2010, alleging default.
- October 12, 2011: RPVI filed Civil Case No. 4263 for nullity of the rescission, specific performance, sums of money, etc., against Nestor and Ramones’ heirs.
- Nestor defaulted; RTC (April 12, 2013) dismissed RPVI’s complaint with prejudice, finding badges of fraud and that Nestor had no title to sell.
- CA (May 26, 2016) reversed, characterizing the deed as a contract to sell, applying R.A. 6552 (Maceda Law), and ordering RPVI to pay balance of ₱4,432,500 within 60 days, upon which Nestor would execute the deed of absolute sale. CA denied reconsideration (February 7, 2017).
- RPVI petitioned the Supreme Court for review on certiorari.
Issues:
- Whether a party declared in default in the trial court may nonetheless file an appellee’s brief in the appellate court.
- Whether Nestor’s rescission (cancellation) of the April 11, 2007 Deed of Conditional Sale is valid.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)