Case Digest (G.R. No. 119466)
Facts:
In Salvador Adorable and Ligaya Adorable v. Court of Appeals, Hon. Jose O. Ramos, Francisco Bareng and Saturnino Bareng (G.R. No. 119466, November 25, 1999), petitioners Salvador and Ligaya Adorable were lessees of a 200-sq.m. portion of Lot No. 661-D-5-A, registered in the name of Saturnino Bareng under TCT No. T-162837, located in San Fabian, Echague, Isabela. On April 29, 1985, Saturnino Bareng and his son Francisco borrowed ₱26,000 from the Adorables in exchange for the fruits and enjoyment of Lot No. 661-E (TCT No. T-60814). On August 3, 1986, Saturnino sold 18,500 sq.m. of Lot 661-D-5-A to Francisco, and on August 27, 1986, Francisco sold 3,000 sq.m. of the same lot to Jose Ramos, including the portion leased to petitioners. The deeds were not registered. After Francisco failed to repay the loan or comply with a mediated compromise agreement admitting indebtedness, petitioners filed a complaint in RTC Branch 24, Echague, for annulment or rescission of the sale as fraudulenCase Digest (G.R. No. 119466)
Facts:
- Parties and Property
- Private respondent Saturnino Bareng was the registered owner of two parcels in San Fabian, Echague, Isabela:
- Lot No. 661-D-5-A (20,000 sq. m., TCT No. T-162837)
- Lot No. 661-E (4.0628 ha., TCT No. T-60814)
- Petitioners spouses Salvador and Ligaya Adorable were lessees of a 200 sq. m. portion of Lot No. 661-D-5-A.
- Loan, Conveyances, and Default
- April 29, 1985: Saturnino and his son Francisco Bareng borrowed P26,000 from petitioners, promising possession and fruits of Lot No. 661-E.
- August 3, 1986: Saturnino sold to Francisco 18,500 sq. m. of Lot No. 661-D-5-A (annotated on TCT No. T-162873).
- August 27, 1986: Francisco sold 3,000 sq. m. of the same lot to Jose Ramos; these deeds were not registered; the portion leased to petitioners was included.
- Francisco failed to repay; compromise before INP Captain Saet acknowledged P56,385.00 due July 15, 1987; he still defaulted.
- Judicial Proceedings
- Petitioners filed an R.T.C. Branch 24 complaint for annulment or rescission of the sale to Ramos on grounds of fraud.
- At trial, petitioners presented Ramos as witness but were absent on August 4–5, 1990; court terminated their evidence and allowed respondents to present theirs ex parte.
- February 15, 1991: R.T.C. dismissed the complaint for lack of cause of action, upheld the sale contract, and ordered Francisco to pay his debt.
- The Court of Appeals affirmed with a modification of the debt amount. Petitioners then filed a Rule 45 petition before the Supreme Court.
Issues:
- Cause of Action
- Did the Court of Appeals err in dismissing the complaint for lack of cause of action?
- Preference Right
- Do petitioners enjoy a legal preference to purchase the leased lots under Commonwealth Act No. 539?
- Trial Procedure
- Did the appellate court err in sustaining the trial court’s termination of petitioners’ evidence and allowing respondents to present theirs ex parte?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)