Case Digest (G.R. No. 157434)
Facts:
- The case involves the Spouses Claro and Nida Bautista (petitioners) and Berlina F. Silva, represented by Hermes J. Dorado (respondent).
- Berlina and her husband, Pedro M. Silva, were the registered owners of a parcel of land in Valenzuela, Metro Manila, under Transfer Certificate of Title No. B-37189, registered on August 14, 1980.
- On March 3, 1988, Pedro, acting as Berlina's attorney-in-fact through a Special Power of Attorney (SPA) allegedly executed on November 18, 1987, sold the property to the Bautistas.
- The title was transferred to the Bautistas, resulting in the issuance of Transfer Certificate of Title No. V-2765 on March 4, 1988.
- Berlina later filed a complaint for annulment of the deed of sale and the transfer certificate in the Regional Trial Court (RTC) of Valenzuela, claiming the SPA was forged and that Pedro lacked authority to sell without her consent.
- The RTC found the signature on the SPA was forged, rendering the sale null and void, and ordered the reconveyance of the property to Berlina, awarding her attorney's fees.
- The Bautistas appealed to the Court of Appeals (CA), which affirmed the RTC's ruling.
- The Bautistas subsequently filed a petition for review on certiorari with the Supreme Court, arguing they were buyers in good faith and that Dorado lacked authority to represent Berlina.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the Court of Appeals' decision, ruling that the Bautistas were not buyers in good faith.
- The Court held that the complaint filed by Berlina was valid, as she personally signed the verification and testified in the case.
- The Court ruled that the Bautistas could...(Unlock)
Ratio:
- The Supreme Court emphasized that to be considered a buyer in good faith, one must demonstrate reliance on the seller's title and capacity to sell.
- The Bautistas failed to conduct a thorough inquiry into Pedro's authority to sell, especially since Berlina was in Germany at the time of the sale.
- The SPA presented by the Bautistas was a mer...continue reading
Case Digest (G.R. No. 157434)
Facts:
The case involves the Spouses Claro and Nida Bautista (petitioners) and Berlina F. Silva, represented by Hermes J. Dorado in his capacity as Attorney-in-Fact (respondent). The events leading to the case began when Berlina and her husband, Pedro M. Silva, were the registered owners of a parcel of land in Valenzuela, Metro Manila, under Transfer Certificate of Title No. B-37189, registered on August 14, 1980. On March 3, 1988, Pedro, acting as Berlina's attorney-in-fact through a Special Power of Attorney (SPA) allegedly executed on November 18, 1987, sold the property to the Bautistas. Following this transaction, the title was transferred to the Bautistas, resulting in the issuance of Transfer Certificate of Title No. V-2765 on March 4, 1988.
However, Berlina later filed a complaint for annulment of the deed of sale and the transfer certificate in the Regional Trial Court (RTC) of Valenzuela, claiming that the SPA was a forgery and that Pedro lacked the authority to sell the property without her consent. The RTC found that the signature on the SPA was indeed forged, rendering the sale null and void. The court ordered the reconveyance of the property to Berlina and awarded her attorney's fees. The Bautistas appealed the RTC's decision to the Court of Appeals (CA), which affirmed the RTC's ruling. The Bautistas subsequently filed a petition for review on certiorari with the Supreme Court, arguing that they were buyers in good faith and that the...