Case Digest (G.R. No. 211170)
Facts:
In Spouses Maximo Espinoza and Winifreda De Vera vs. Spouses Antonio Mayandoc and Erlinda Cayabyab Mayandoc (G.R. No. 211170, July 3, 2017), a parcel of land in Dagupan City was originally owned by Eusebio Espinoza and, upon his death, divided among his heirs: Pastora, Domingo, and Pablo Espinoza. Domingo’s son, petitioner Maximo Espinoza, and his co-petitioner wife Winifreda De Vera, claimed a three-fourth share following their father’s death in 1965. On May 25, 1972, Pastora sold her one-fourth share to respondents Antonio and Erlinda Mayandoc and Leopoldo Espinoza. That same day, Domingo purportedly sold the remaining three-fourths to Erlinda’s parents via a fictitious deed, spawning Title Certificate (TCT) No. 28397. On July 9, 1977, a second fraudulent deed conveyed the entire parcel to the Mayandocs under TCT No. 37403. Petitioners successfully obtained in 1999 an RTC judgment annulling both deeds and ordering reconveyance; the CA affirmed in 2004, final and executory on MCase Digest (G.R. No. 211170)
Facts:
- Ownership and Succession
- A parcel of land in Dagupan City was originally owned by Eusebio Espinoza and, upon his death, divided among his heirs Pastora, Domingo, and Pablo Espinoza.
- Domingo Espinoza (father of petitioner Maximo) died in 1965; his spouse Agapita Cayabyab died in 1963.
- Conveyances and Title Registrations
- On May 25, 1972, Pastora Espinoza sold her undivided one-third share to respondents Antonio and Erlinda Mayandoc and to Leopoldo Espinoza.
- On the same date, a fictitious deed of sale by Domingo purported to convey three-fourths of the estate to Erlinda’s parents, resulting in TCT No. 28397.
- On July 9, 1977, another fictitious deed by Nemesio Cayabyab, Candida Cruz, petitioners, and Leopoldo Espinoza conveyed the entire parcel to respondents, resulting in TCT No. 37403.
- Annulment Proceedings
- Petitioners filed for annulment of documents and nullification of TCT No. 37403; on August 16, 1999, RTC Branch 40 ruled in their favor, ordering reconveyance and attorney’s fees.
- On February 6, 2004, the CA affirmed the RTC decision with deletion of attorney’s fees; this decision became final and executory on March 8, 2004.
- Complaint for Useful Expenses and Subsequent Proceedings
- Respondents filed a complaint under Articles 448 and 546 of the New Civil Code, claiming reimbursement of P800,000 for a house built in good faith in 1995–1996 on the disputed land.
- Petitioners answered that respondents knew the deeds were fictitious and thus were bad-faith builders not entitled to indemnity.
- On January 5, 2011 respondents opted to buy the land; petitioners declined both to sell the land and to buy the house.
- On February 18, 2011, RTC Branch 42 ordered petitioners to sell the land at BIR zonal value.
- On September 17, 2013, the CA affirmed with modifications, remanding for proper application of Articles 448, 546, and 548 of the Civil Code.
- On January 28, 2014, the CA denied petitioners’ motion for reconsideration.
- On March 21, 2014, petitioners filed a Petition for Review under Rule 45 before the Supreme Court.
Issues:
- Whether the CA erred in ruling that petitioners failed to prove respondents’ bad faith in constructing the improvements.
- Whether the CA erred in ruling that res judicata does not apply to bar the complaint for reimbursement of useful expenses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)