Case Digest (G.R. No. 116734)
Facts:
The dispute concerns Lot No. 2836 in Zamboanga City, originally co-owned by Luis and Isidro Bonifacio. In 1961, petitioners Spouses Eulalio and Flora Bonifacio Cueno acquired Isidro’s undivided share (“first sale”), which resulted in TCT No. T-20,676 issued in Luis and Eulalio’s names in April 1967. However, on December 4, 1963, Eulalio purportedly sold his and Flora’s conjugal interest back to Luis without Flora’s concurrence (“second sale”), later generating TCT No. T-20,677 in Luis’s sole name. Thereafter, on August 12, 1977, Luis executed a “third sale” to Spouses Epifanio and Veronica Bautista, who obtained TCT No. T-49,239 and, in 2005, donated the parcel to their four children, the respondents. Claiming fraud and lack of spousal consent, petitioners filed in November 2008 a complaint for recovery of conjugal shares, nullity of the second sale, and cancellation of subsequent titles. The Regional Trial Court (RTC) in February 2017 declared the second sale void for lack of FCase Digest (G.R. No. 116734)
Facts:
- Ownership and Parties
- Lot No. 2836 was originally co-owned by Luis and Isidro Bonifacio; they sold part to the City of Zamboanga and retained about 7,991 sqm.
- Petitioners Spouses Eulalio and Flora Bonifacio Cueno are married; Flora is daughter of Luis and Juana Toribio.
- Sequence of Conveyances
- First Sale (Oct. 23, 1961): Petitioners purchased Isidro’s pro indiviso share; TCT No. T-20,676 issued on Apr. 13, 1967 in names of Luis and Eulalio.
- Second Sale (Dec. 4, 1963): Eulalio allegedly sold his and Flora’s share to Luis without Flora’s consent; same‐day registration led to TCT No. T-20,677 in Luis’s name.
- Third Sale (Aug. 12, 1977): Luis sold the entire property to Spouses Epifanio and Veronica Bautista; TCT No. T-49,239 issued.
- Donation (Oct. 14, 2005): Respondents donated the property to their four children, who obtained respective Torrens titles.
- Litigation History
- Complaint filed Nov. 10, 2008: Petitioners sought recovery of shares, annulment of the second sale and donation, and cancellation of subsequent titles.
- RTC Decision (Feb. 1, 2017): Held second sale void for lack of spousal consent; declared all subsequent titles void but awarded respondents indemnity for improvements.
- CA Decision (Oct. 8, 2018): Reversed RTC; dismissed petitioners’ complaint; ruled respondents were innocent purchasers for value relying on TCT No. T-20,677.
Issues:
- Validity of the Second Sale
- Is the second sale without spousal consent void or merely voidable?
- What is the effect on subsequent transfers and Torrens titles?
- Rights of Respondents as Purchasers
- Were respondents innocent purchasers for value and in good faith?
- Does the Torrens system protect them despite alleged antecedent defects in title?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)