Case Digest (G.R. No. 125233) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Alexander Cruz and Adelaida Cruz v. Eleuterio Leis et al., G.R. No. 125233 (March 9, 2000), private respondents Eleuterio Leis, Raymundo Leis, Anastacio L. Lagdano and Loreta L. Cayonda, heirs of spouses Adriano Leis and Gertrudes Isidro, filed a petition before the Regional Trial Court (RTC) of Pasig to annul two contracts of sale executed on March 11, 1986 by their 80-year-old, illiterate mother, Gertrudes Isidro, in favor of petitioner Alexander Cruz. The parties agreed that one contract was a pacto de retro ("Kasunduan") granting Gertrudes one year to repurchase, and the other an absolute sale ("Kasunduan ng Tuwirang Bilihan") for ₱39,083—the same amount borrowed and secured by mortgage one month earlier. Title to the 100-sqm property in Marikina was consolidated in Cruz’s name on April 21, 1987, as TCT No. 130584. Gertrudes died on June 9, 1987, and her heirs were later asked to vacate. The RTC declared the absolute sale void, ruled the land conjugal upon proof t Case Digest (G.R. No. 125233) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marriage and Acquisition of Property
- Adriano Leis and Gertrudes Isidro were married on 19 April 1923.
- On 27 April 1955, Gertrudes acquired from the Department of Agriculture and Natural Resources a 100-sq.m. lot in Bo. Sto. Niño, Marikina, Rizal, covered by TCT No. 42245, described as “Gertrudes Isidro, widow.”
- On 2 March 1956, TCT No. 43100 was issued in the name of “Gertrudes Isidro,” likewise as “widow.”
- Loan, Contracts of Sale, and Transfer of Title
- On 5 February 1985, Gertrudes borrowed ₱15,000 from spouses Alexander and Adelaida Cruz at 5% interest, secured by a mortgage on TCT No. 43100.
- Failing to pay by 5 February 1986, she executed on 11 March 1986:
- A “Kasunduan” (pacto de retro sale), granting her one year to repurchase.
- A “Kasunduan ng Tuwirang Bilihan” (deed of absolute sale) over the same property for ₱39,083.00.
- Upon failure to repurchase, title consolidated in Alexander Cruz; TCT No. 130584 was issued on 21 April 1987.
- Death, Ejectment Demand, and Litigation
- Gertrudes died on 9 June 1987, intestate. Her heirs (private respondents) then received ejectment demands from petitioners.
- Private respondents sued in the RTC of Pasig to nullify the absolute sale and title, alleging:
- Fraud (due to Gertrudes’ illiteracy and age).
- Undervaluation of the property.
- Conjugal nature of the land—sale effected without spousal consent.
- The RTC declared the absolute‐sale contract and TCT No. 130584 null and void, ruled the property conjugal, reinstated TCT No. 43100, and awarded damages and attorney’s fees.
- The Court of Appeals affirmed; petitioners appealed to the Supreme Court.
Issues:
- Was the disputed property conjugal or Gertrudes’ exclusive (paraphernal) property?
- Does redemption from a prior mortgage foreclosure terminate co‐ownership and vest exclusive title in Gertrudes?
- Does failure to obtain a judicial order under Article 1607, Civil Code, invalidate the consolidation of ownership in the vendee a retro?
- What is the effect of Gertrudes’ failure to repurchase under the pacto de retro on title and ownership?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)