Case Digest (G.R. No. 183141)
Facts:
The case involves a dispute over ownership of Lot No. 19986 located in Tablon, Cagayan de Oro City. The lot originally measured 1,015 square meters and was initially owned by Spouses Azur Pastrano and Profitiza Ebaning Pastrano. On November 18, 1968, the Pastranos sold the property to Eustaquio P. Ledesma, Jr., who in turn sold a 200-square meter portion to petitioners Spouses Magdalino and Cleofe Badilla in 1970 on an installment basis without a written contract but delivered possession to them. Subsequently, on April 18, 1978, Spouses Florito and Fe Bragat acquired 991 square meters of the lot from Ledesma via deed of absolute sale, with tax declarations issued for two lots labeled 19986-A and 19986-B.
Despite these transactions, on May 5, 1984, and again on October 2, 1987, the Pastranos executed deeds of sale of the entire 1,015 square meter property to Fe Bragat and obtained Transfer Certificate of Title (TCT) No. T-47759 in her name, canceling the original certificate (OC
...
Case Digest (G.R. No. 183141)
Facts:
- Ownership and transactions involving the subject property
- Azur Pastrano and his wife Profitiza Ebaning (Spouses Pastrano) were originally owners of Lot No. 19986, located in Tablon, Cagayan de Oro City, covered by Original Certificate of Title (OCT) No. P-2035 issued on November 18, 1980, in Azur Pastrano's name.
- Prior to the OCT issuance, on November 18, 1968, the Spouses Pastrano sold the lot to Eustaquio P. Ledesma, Jr. (Ledesma), documented by a Deed of Definite Sale of Unregistered Coconut and Residential Land.
- In 1970, the Spouses Magdalino and Cleofe Badilla (Spouses Badilla) allegedly purchased from Ledesma, on an installment basis, a 200 sq. m. portion of Lot No. 19986 (designated as Lot No. 19986-B), with possession transferred to them although no written contract was executed.
- On April 18, 1978, Spouses Florito and Fe Bragat (Spouses Bragat) bought 991 sq. m. from Ledesma via a Deed of Absolute Sale; two tax declarations were issued for Lot No. 19986-A (642 sq. m.) and Lot No. 19986-B (349 sq. m.).
- On May 5, 1984, the Spouses Pastrano executed a Deed of Absolute Sale in favor of Fe Bragat covering the entire 1,015 sq. m., reflected in OCT No. P-2035. On the same day, Azur Pastrano reported loss of the owner's duplicate copy of the OCT.
- Bragat petitioned the RTC for issuance of a new owner's duplicate of OCT No. P-2035; the court ordered issuance on July 24, 1987.
- On October 2, 1987, Spouses Pastrano executed another Deed of Sale covering the same size and property to Bragat; OCT No. P-2035 was canceled and Transfer Certificate of Title (TCT) No. T-47759 was issued in Bragat's name.
- Conflict over possession and title
- On March 7, 1991, Bragat demanded possession from Spouses Badilla who refused, asserting prior acquisition from Ledesma through the sale by Spouses Pastrano to Ledesma and further sale by Ledesma to them.
- Both parties filed suits: Bragat filed a Complaint for Recovery of Possession and Damages (June 5, 1992) asserting ownership through her title; Badillas filed a Complaint for Quieting of Title, Nullity of TCT No. T-47759, and Damages (June 11, 1992) claiming lawful ownership and possession of Lot No. 19986-B since 1970 from Ledesma.
- Proceedings and decisions below
- The Regional Trial Court (RTC), after trial and consolidation of cases, favored Bragat, noting her title and purchase in good faith; dismissed Badillas' complaint for failure to substantiate claims, and ordered Badillas to vacate the portion occupied, pay damages, rental, attorney's fees, and costs.
- The Court of Appeals (CA) affirmed the RTC decision but modified it by recognizing that Ledesma sold only 991 sq. m. to Bragat in 1978, thus the remaining 24 sq. m. belonged to Badillas and should be reconveyed. The CA deleted the award of damages and ordered remand for determination of the 24 sq. m. portion.
- Appeal before the Supreme Court
- Spouses Badilla filed a petition for review assailing the CA decision, asserting ownership based on purchase from Ledesma and possession since 1970, claiming delivery of the owner’s duplicate copy of OCT No. P-2035 from Pastrano to Ledesma and then to them.
- They alleged fraud in Bragat’s claim of loss of title and in the Deed of Sale dated October 2, 1987, arguing that Profitiza Pastrano, who supposedly signed the deed, had been deceased since 1985.
- Bragat countered that October 2, 1987 sale was a “re-execution” to avoid tax penalties and that Badillas’ documentary evidence was executed after Bragat’s acquisition and titling.
Issues:
- Whether ownership of the 152-sq.-m. portion of Lot No. 19986 was validly transferred to the Spouses Badilla in 1970 through the sale from Ledesma, despite the absence of a written contract.
- Whether the Deeds of Sale executed by the Spouses Pastrano in favor of Fe Bragat dated May 5, 1984 and October 2, 1987 are valid and effective in transferring ownership.
- Whether Transfer Certificate of Title No. T-47759 issued to Fe Bragat is valid with respect to the entire property including the disputed 152-sq.-m. portion.
- Whether the principle of good faith and priority of registration applies in this case of multiple sales and conflicting claims of ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)