G.R. No. 202284 - Seming vs. Alamag

Petitioner Cristina R. Seming (spouses Seming) and respondents Emelita P. Alamag, Violeta L. Pamat, Rolando L. Pamat, and Fernando L. Pamat (respondents/spouses Pamat).
The dispute concerns one-half portion (771 square meters) of Lot 512-C (total 1,542 square meters), Barangay Bay, Ligao City, titled under Jesusa Seming Vda. De Lopez (Jesusa) and spouses Pamat (TCT No. T-134781).

In 1977, spouses Seming allegedly purchased Jesusa’s half-share (771 sqm) of Lot 512-C and constructed a conjugal dwelling thereon; Jesusa executed a Deed of Sale.
The spouses Seming also claimed a verbal agreement with spouses Pamat for the purchase of the other half (771 sqm), but no written document was executed at that time.
Petitioner assumed litigation expenses in a quieting of title case (Civil Case No. 744) regarding Lot 512-C, with agreement that such expenses would offset part of the purchase price for the subject property.
Petitioner paid part of the purchase price for the subject property both in cash and in kind.
In 1990 and 1991, allegedly, petitioner received two receipts acknowledging partial payments of P6,000 each from Natividad Pamat for two 200 sqm portions of the subject property, both signed by Natividad and witnessed by Jesusa.
By 1983, litigation finalized and by agreement, Natividad was to pay petitioner another 200 sqm portion, totaling 600 sqm out of 771 sqm owned by Natividad.
In 2002, petitioner offered to buy the remaining 171 sqm from spouses Pamat for P10,000, but respondents refused, denying any sale.
Respondents claimed no sale was made and retained ownership and possession of their share. They also argued the petition was void due to prescription.

Ordered respondents to execute a Deed of Absolute Sale for 600 sqm of Lot 512-C in favor of petitioner.
Awarded nominal damages of P40,000 and attorney’s fees of P60,000 to petitioner.
Held that a contract of sale existed supported by consent, determinate subject, and price certain, relying heavily on the receipts and possession/improvements by petitioner.

The Court of Appeals (CA), on July 22, 2011, reversed the RTC decision, ruling no contract of sale existed:

No meeting of minds and no valid consent between petitioner and spouses Pamat on the sale of the subject property.
The receipts were not properly proven authentic and were ambiguous in terms of object and price.
Petitioner’s possession was only on Jesusa’s portion, not respondents’.
The CA deleted the award of damages and attorney’s fees for lack of basis.

Petitioner’s Motion for Reconsideration was denied in the CA Resolution dated May 21, 2012.
Petitioner filed the present Petition for Review on Certiorari before the Supreme Court.

Whether there was a perfected contract of sale over the subject portion of Lot 512-C between petitioner and respondents.
Whether the October 22, 1990 and January 23, 1991 receipts were properly executed, authentic, and admissible as evidence to prove the sale.