Title
Spouses Espinoza vs. Spouses Mayandoc
Case
G.R. No. 211170
Decision Date
Jul 3, 2017
A land dispute involving annulled deeds, good faith construction, and reimbursement claims under Articles 448, 546, and 548 of the Civil Code, remanded for valuation.
A

Case 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)

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