Case Digest (G.R. No. 157701)
Facts:
Spouses Danilo and Alberta Domingo, and Eduardo Quiteves v. Guillermo Reed, G.R. No. 157701, December 09, 2005, Supreme Court Third Division, Panganiban, J., writing for the Court.Respondent Guillermo Reed purchased a 166-square-meter lot from the GSIS while working abroad; the title (TCT No. 58195) was issued on July 9, 1986 in the name of Lolita Reed, married to Guillermo Reed. While Guillermo was overseas (1978–1986), his wife Lolita paid installments and later allegedly effected several sales of portions of the lot to third parties who obtained separate titles: a 41.5 sq.m. portion to Spouses Danilo and Alberta Domingo (Deed dated July 14, 1986; TCT No. 84567), an 86 sq.m. portion to Eduardo Quiteves (Deed dated January 10, 1989; TCT No. 84565), and another portion to spouses Ardaniel and Natividad Villanera (TCT No. 84566).
When Dominador and Luz Reed (occupants) were served in December 1991 in an ejectment complaint by Quiteves, Guillermo checked the Pasig Register of Deeds and discovered that his title had been cancelled and that TCTs had been issued to the vendees. Guillermo secured copies of a Special Power of Attorney (SPA) dated July 8, 1986 allegedly executed by him authorizing Lolita to sell, the deeds of sale, and the subsequently issued TCTs.
On March 8, 1994, Guillermo filed a complaint for reconveyance in the Regional Trial Court (RTC) of Pasig against Lolita, the vendees (including petitioners), and the Register of Deeds of Pasig, alleging the SPA was forged and that the sales were void. The vendees answered asserting the presumption of regularity of notarized documents and that they were purchasers in good faith. Service on Lolita and some vendees was defective; Lolita was not served but later filed a Petition-in-Intervention in the Supreme Court.
The RTC rendered judgment dismissing Guillermo’s complaint for lack of merit, effectively upholding the vendees’ titles. The Court of Appeals (CA), however, on August 27, 2002, reversed the RTC: it found the SPA to be forged, discredited the barangay minutes purporting Guillermo’s admission, relied on a Regional Trial Court clerk’s certification that the notarized SPA was not the one appearing in the notarial report of Atty. Macario Cruz, and noted chronological irregularities (the SPA’s date preceding TCT issuance). The CA declared the deeds of sale in favor of the Domingos and Quiteves null and void, ordered cancellation of the corresponding TCTs, and reinstated TCT No. 58195 insofar as it covered the sold portions; it did not adjudicate the Villaneras’ rights for lack of personal service. The CA’s March 20,...(Subscriber-Only)
Issues:
- Procedural: Whether the trial court’s alleged lack of jurisdiction over the person of Lolita Reed (an indispensable party not served with summons) bars Guillermo Reed’s reconveyance action from prospering.
- Substantive: Whether the Special Power of Attorney dated July 8, 1986 is authentic.
- Substantive: Whether Lolita Reed’s asserted justification—use of sale proceeds for family necessities or alleged donations to children—validly binds the conjugal partnership and validates the sales.
- Substantive: Whether petitioners were purchasers in good faith and for val...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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