G.R. No. 143325 - Santos vs. Heirs of Mariano

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G.R. No. 143325: Santos vs. Heirs of Mariano

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Title Source: Supreme Court: Santos vs. Heirs of Mariano

Case: G.R. No. 143325

Decision Date: Oct 24, 2000

Heirs contested Irene's unauthorized property sales; courts ruled deeds null, restored ownership, and awarded damages due to lack of valid consent.

Case Digest (G.R. No. 143325)
Expanded Legal Reasoning Model

Facts:

Ownership and Inheritance of the Land

Original Owners:

Macario A. Mariano and Irene PeAa-Mariano owned six (6) parcels of land covered by five (5) land titles:

Lot 15-A (TCT No. 1962)
Lot 15-B (TCT No. 1963)
Lot 15-C (TCT No. 1964)
Lots 545 and 2348 (TCT No. 259)
Lot 612 (TCT No. 219)

Succession and Indenture Agreement:

Macario died intestate on December 2, 1972.
His share passed to his heirs: Irene, Jose P. Mariano, and Erlinda Mariano-Villanueva.
The heirs executed an “Indenture of Extra-Judicial Settlement of Estate” (Exhibit “B”).
New titles were issued in the names of the heirs except for Lot 612, which remained exclusively with Irene initially (later TCT No. 7257).

Appointment of Representative:

Jose and Erlinda appointed Irene as their lawful representative and agent for management, administration, and disposition of the estate.
Though not explicitly authorized for mergers, Irene executed an Affidavit of Merger consolidating titles:

TCT Nos. 6565, 6566, 6567, and 6562 were replaced by new titles – TCT Nos. 7757, 7260, 7261, and 7258 respectively.
TCT No. 7257 remained in Irene’s name.

Conveyance of the Land

Subsequent Marriage and Sale:

On December 9, 1974, Irene married Rolando Relucio, a traveling salesman. At the time, Irene was 58 years old and Rolando was 45.
The marriage was later annulled by the RTC Naga City on December 16, 1991 due to Rolando’s prior marriage.

Deed of Absolute Sale (First):

On April 15, 1975, Irene executed a Deed of Absolute Sale (Exhibit “G”) selling all six parcels of land to Raul Santos (Rolando’s first cousin) for ₱150,000.00.
Although notarized by Jose S. PeAaas, the transfer of titles to Raul was delayed.

Subsequent Transactions:

On June 7, 1979, Irene sold Lot 612 (TCT No. 7257) to Greta Tinga de los Reyes, which was later conveyed to Bonifacio Sia, Jr.
On March 10, 1982, a second Deed of Absolute Sale was executed in favor of Raul covering Lots 545 and 2348 for ₱129,550.00; these were later registered under TCT No. 13402.
On October 2, 1987, the remaining three lots (15-A, 15-B, and 15-C) were transferred to Raul:

Lot 15-A: TCT No. 17747
Lot 15-B: TCT No. 17746
Lot 15-C: TCT No. 17745

Further Dispositions:

On August 9, 1990, Lot 15-A (TCT No. 17747) was transferred to Amado Sanao via a Deed of Sale with Real Estate Mortgage; the title was cancelled and reissued as TCT No. 20747.
Lot 15-C had been levied in favor of Francisco Bautista, sold at public auction to Ruben Sia, and issued under TCT No. 20201.

Possession and Improvements:

Despite the sale, Irene continued to possess, manage, and collect income from Lots 15-A, 15-B, 545, and 2348.
In 1981, she used her funds to construct a two-storey commercial building on Lots 545 and 2348 (initially “IPR Building III” later renamed “Monica Inn”).

Demise of Key Parties:

Irene died on June 26, 1988, leaving her judicially adopted children, Jose and Erlinda, as her only compulsory heirs.
Rolando died on January 30, 1990.
Only after Irene’s death did Jose and Erlinda learn of the disposition of the properties in favor of Raul.

Pre-Litigation Developments and Administrative Complaints

Discovery and NBI Examination:

Jose and a certain Francisco Bautista caused an expert examination of the Deed of Absolute Sale dated April 15, 1975 by the National Bureau of Investigation.
The NBI Report found:

The typewritten entries in question were not produced from the same typewriter.
Three pages of the document were not original.

Administrative Complaints:

Based on these findings, Jose and Francisco Bautista filed two administrative complaints against Judge Jose PeAaas (Adm. Case No. 3247 and Adm. Matter No. 121-J-88-226).
The Supreme Court later absolved Judge PeAaas.
The Court noted in Mariano vs. PeAaas that there was no evidence to support that Irene’s signature was forged.

Litigation Arising from the Deeds of Sale

Annulment and Cancellation Actions:

A suit for annulment of sale with damages (Civil Case No. 88-1506) was filed on July 18, 1988 by Jose and Erlinda against Rolando, Raul, and the Register of Deeds.
After the death of Jose (December 2, 1989) and Rolando (January 30, 1990), substitutions were made for the deceased parties.

Separate Action on Title and Deed of Sale:

On November 27, 1990, an action for annulment of title and the deed of sale covering Lots 545 and 2348 was filed (Civil Case No. 90-2218) against Rolando, Raul, and the Register of Deeds.
The cases were consolidated for joint trial.

Intervention by the Law Firm:

The Law Firm of San Buenaventura, Moraleda, Obias and Yambao filed a Motion for Leave to Intervene based on their contingent fee arrangement with Erlinda.
Their intervention was granted.

Joint Judgment and Appeals:

A Joint Judgment dated July 22, 1994, was rendered in favor of the defendants-appellees (Rolando, Raul, and the Register of Deeds).
Separate appeals, including one by Raul regarding damages, were interposed; however, Raul eventually withdrew his appeal.

Motion for New Trial:

Plaintiffs-appellants later filed a Motion for New Trial based on newly discovered evidence.
The Supreme Court granted the Motion for New Trial on March 31, 1998.
During the new trial hearing on May 8, 1998, plaintiffs-appellants presented three witnesses and documentary evidence.

Court of Appeals Decision:

The Court of Appeals rendered judgment declaring the Deeds of Absolute Sale dated April 15, 1975 and March 10, 1982, and the Deed of Sale with Real Estate Mortgage dated August 9, 1990 as null and void.
Titles (TCT Nos. 17746, 17747, 13402, and 20747) were cancelled and new titles issued in the name of Irene’s heirs.
Monetary awards were granted for moral damages and attorney’s fees.

Motion for Reconsideration:

Petitioner filed a Motion for Reconsideration on December 27, 1999.
The Court of Appeals denied the motion on May 19, 2000, while granting a Supplemental Motion to restore possession and administration of the properties to the heirs.

Final Petition and Arguments on Appeal

Subject Matter of the Petition:

The central issue was the validity of the contracts of sale executed by Irene and whether the transactions were bona fide and binding on the heirs, as co-owners.

Petitioner’s Arguments:

The petitioner argued that:

The Court of Appeals erred by disregarding the Supreme Court in Mariano vs. PeAaas which validated "Exhibit G" and by erroneously ruling the deeds simulated and void.
The Court allowed newly discovered evidence that did not qualify under the established rules.
There was grave abuse of discretion in restoring possession and administration to the heirs while the appellate decision was not final.

Court’s Response:

The Court reiterated that:

The validity of a contract hinges on consent, a certain object, and the cause of the obligation.
There was no meeting of minds between the seller (Irene) and the buyers.
The petitioner’s procedural objections regarding newly discovered evidence were moot since he had opportunity to contest them at the hearing.
Restoring possession temporarily was not reversible given the pending finality of the resolution.

Issues:

Validity of the Contracts of Sale

Whether the Deed of Absolute Sale dated April 15, 1975 (and the subsequent deed dated March 10, 1982) constituted valid, binding contracts despite allegations of forgery or simulation.
Whether there was a true meeting of the minds between the purported vendor, Irene, and the buyers, considering the evidence suggesting a lack of genuine intent to sell.

Permissibility of Admitting Newly Discovered Evidence

Whether the newly discovered documents and evidence presented at the new trial were admissible under the rules.
Whether the admission of such evidence altered the outcome of the previous ruling or was procedurally improper.

Procedural and Jurisdictional Concerns

Whether the Court of Appeals committed reversible error by granting the motion to restore possession and administration of the properties to Irene’s heirs.
The effect of the Court of Appeals’ decision regarding interim relief on the final disposition of the title matters.
Whether the petitioner’s participation in the hearing negated his later procedural objections.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

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END