Case Digest (G.R. No. 196743)
Facts:
The case involves petitioners spouses Lolito Chua and Myrna Palomaria, and spouses Sergio Chua (deceased) and Elena Chua, as well as respondents spouses Agustin Lo and Josefina N. Becina, Victor Lo, and Agustin Lo Realty Corporation. The dispute concerns ownership and possession over parcels of land located in Sta. Cruz, Laguna, originally covered by Original Certificate of Title No. P-3264. The spouses Chua owned the entire Lot 505 (21,644 square meters), which was sold in parcels in 1975, 1976, and 1977 to respondents Josefina and Delia Becina. Specifically, sales were made covering a total of 5,012 square meters (4,612 sq m in 1976 and 400 sq m in 1977). Subsequent subdivisions of Lot 505 resulted in Lot 505-B, subdivided into Lot 505-B-1, 505-B-2, and 505-B-3. Lot 505-B-3 was further subdivided into Lot 505-B-3-A (600 sq m) and 505-B-3-B (1,478 sq m).
While Lot 505-B-2 was conveyed to Josefina through a Deed of Sale in 1984 and titled under TCT No. T-101045, Lot 505-B-3 wa
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)