Case Digest (G.R. No. 129103)
Facts:
Claudio Delos Reyes and Lydia Delos Reyes v. The Hon. Court of Appeals and Daluyong Gabriel, substituted by his heirs Maria Luisa G. Esteban, Maria Rita G. Bartolome & Renato Gabriel, G.R. No. 129103, January 29, 2001, Supreme Court Third Division, Gonzaga-Reyes, J., writing for the Court.Petitioners spouses Claudio and Lydia Delos Reyes occupied and improved a 300-square-meter portion of a 5,010-square-meter parcel registered under TCT No. T-17932 in the name of private respondent Daluyong Gabriel, who had acquired the lot by hereditary succession in 1974. Because Daluyong and his family resided in Mandaluyong, his sister Maria Rita Gabriel de Rey acted as administratrix and collected rentals; Lydia De los Reyes first leased 176 sq.m. under a June 21, 1985 lease, later novated on September 26, 1985 to a six-year lease with Renato Gabriel as lessor, who acknowledged advanced rental payments.
In November 1987 Lydia allegedly agreed verbally to buy 250 sq.m. (including the 176-sq.m. leased portion) plus an additional 50 sq.m., totaling 300 sq.m., at P300 per sq.m. (P90,000). Payment in installments was evidenced by receipts signed by Renato Gabriel dated November 25, 1987 through February 29, 1988. Petitioners thereafter constructed a two-storey commercial building on the lot. No deed of sale was executed.
Upon learning of the construction, Daluyong (through counsel) demanded cessation on August 30, 1989; petitioners replied on September 20, 1989 asserting good-faith purchase from Renato, who they believed was authorized as administrator. Daluyong sued the De los Reyeses on November 14, 1989 for recovery of possession (RTC Branch I, Tagum, Civil Case No. 2326); the De los Reyeses counter-filed a complaint for specific performance (docketed as Civil Case No. 2327) praying for a deed of conveyance for the 300 sq.m.
The Regional Trial Court consolidated Civil Case Nos. 2326 and 2327 and, in a decision dated September 10, 1991, ordered defendants (Daluyong, Renato and two daughters) to execute a deed of conveyance covering the 300 sq.m. Appellants (the Gabriels) appealed to the Court of Appeals (Sixth Division; Romeo A. Brawner, ponente), which on April 30, 1997 reversed and ordered the De los Reyeses to vacate and turn over possession of the 300 sq.m., holding the oral sale void for lack of authority in Renato.
Petitioners filed a petition for review on certiorari to the Supreme Court (Rule 45), originally docketed June 16, 1997; the Third Division denied it October 13, 1997 but reinstated it on reconsideration December 3, 1997. Daluyong died September 14, ...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit reversible error in declaring the oral contract of sale between petitioners and Renato Gabriel null and void?
- Was petitioners’ claim that title passed to them by operation of law under Article 1434 of the Civil Code valid, on the theory that Renato later acquired title by hereditary succession?
- Are petitioners entitled to restitution of the purchase price and recovery for the improvements t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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