Title
Spouses Chua vs. Spouses Lo
Case
G.R. No. 196743
Decision Date
Aug 14, 2019
Spouses Chua disputed a 600 sq m excess in land sold to Josefina and Delia. SC ruled the excess sale void, quieting title in Sergio Chua’s favor, while upholding the 1975 sale of 500 sq m to Josefina.
A

Case Digest (G.R. No. 196743)

Facts:

  • Ownership and Sale of Lot No. 505
    • Spouses Lolito and Myrna Chua (the spouses Chua) owned Lot No. 505, a coconut land in Sta. Cruz, Laguna, totaling 21,644 sq m, registered under Original Certificate of Title No. P-3264.
    • On January 15, 1976, with Lolito’s consent, Myrna sold a portion of 4,612 sq m of Lot No. 505 to sisters Delia N. Becina and Josefina N. Becina (the Becina sisters).
    • On August 5, 1977, Lolito, again with Myrna’s consent, sold an additional 400 sq m of Lot No. 505 to the same sisters.
    • Thus, Delia and Josefina collectively purchased a total of 5,012 sq m from the spouses Chua via these two sale transactions.
  • Subdivision of Lot No. 505 and Conflicting Claims
    • On March 1, 1978, Lot No. 505 was subdivided into:
      • Lot No. 505-A (14,492 sq m) and
      • Lot No. 505-B (7,152 sq m), the latter registered under Lolito’s name (TCT No. 83840).
    • Lot No. 505-B was further subdivided into:
      • Lot No. 505-B-1 (1,540 sq m),
      • Lot No. 505-B-2 (3,534 sq m), and
      • Lot No. 505-B-3 (2,078 sq m).
    • Lot No. 505-B-3 was subdivided into two: Lot No. 505-B-3-A (600 sq m) and Lot No. 505-B-3-B (1,478 sq m).
    • Despite the sales, spouses Chua objected to the lots allotted to Delia and Josefina—specifically to Lot Nos. 505-B-2 and 505-B-3—as these totaled 5,612 sq m, 600 sq m more than the 5,012 sq m sold.
  • Agreement and Further Transactions
    • To resolve the dispute during a conference, the parties agreed:
      • Lot No. 505-B-2 (3,534 sq m) be conveyed to Josefina.
      • Lot No. 505-B-3 would remain in Lolito’s name and be subdivided to segregate the extra 600 sq m.
    • Lolito sold Lot No. 505-B-2 to Josefina on February 25, 1984 (consideration: P94,180.00), and TCT No. T-101045 was issued to Josefina.
    • Lot No. 505-B-3 was registered to Lolito (TCT No. T-101046).
    • Lot No. 505-B-3-A (600 sq m) was sold by Lolito to his brother Sergio, evidenced by TCT No. T-114915.
    • Despite this, Josefina and her husband Agustin forcibly occupied all of Lot No. 505-B-3, including the 600 sq m portion belonging to Sergio.
  • Subsequent Events and Dispute
    • Delia died on January 23, 1987; her heirs are Victor Lo (spouse) and their children.
    • On September 12, 1999, Victor sold Lot No. 505-B-3 (2,078 sq m) and a non-existent Lot No. 505-B-4 (428 sq m) to Agustin Lo Realty Corporation.
    • Agustin Lo Realty Corporation occupied the entire Lot No. 505-B-3 and began construction.
    • The spouses Chua demanded that respondents vacate Lot No. 505-B-3-A (600 sq m) and remove structures, which was refused.
    • Respondents acknowledged the 1976 and 1977 deeds of sale but contended that Myrna sold 500 sq m to Josefina in 1975 and that the Chua spouses mortgaged portions of Lot No. 505-B and 505-A-3-B despite prior sales.
    • Respondents claimed the 1984 contract of sale to Josefina included 3,534 sq m:
      • 500 sq m from 1975 sale;
      • 2,506 sq m, Josefina’s share in the 1976 and 1977 sales; and
      • 528 sq m as compensation for damages and inconveniences.
  • Procedural Posture
    • The spouses Chua filed a complaint for quieting of title, annulment of sale, recovery of possession, and damages, seeking to recover Lot No. 505-B-3-A (600 sq m) and to annul the September 21, 1999 deed of sale executed by Victor in favor of Agustin Lo Realty Corporation.
    • The Regional Trial Court ruled in favor of the respondents, dismissed the complaint.
    • The Court of Appeals affirmed the dismissal.
    • Petitioners filed a Petition for Review on Certiorari with the Supreme Court.

Issues:

  • Whether petitioners (spouses Chua and Sergio Chua) are entitled to recover Lot No. 505-B-3-A measuring 600 sq m as the excess area erroneously sold and occupied by respondents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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