Case Digest (G.R. No. 211170)
Facts:
Spouses Maximo Espinoza and Winifreda De Vera v. Spouses Antonio Mayandoc and Erlinda Cayabyab Mayandoc, G.R. No. 211170, July 03, 2017, the Supreme Court Second Division, Peralta, J., writing for the Court.The dispute concerns a parcel of land in Dagupan City originally owned by Eusebio Espinoza and later divided among his heirs Pastora, Domingo, and Pablo Espinoza. Petitioner Maximo Espinoza is a grandson of Domingo. On May 25, 1972, Pastora Espinoza executed a deed of sale conveying her share to respondents and Leopoldo Espinoza, while on the same date a purported (later characterized as fictitious) deed of sale by Domingo Espinoza conveyed a three‑fourths share to respondents’ predecessors, resulting in issuance of TCT No. 28397. On July 9, 1977, another deed (also later deemed fictitious) was executed conveying the land in favor of respondents and TCT No. 37403 was issued in their names.
Petitioners filed an action to annul the documents and nullify TCT No. 37403. On August 16, 1999, the RTC, Branch 40, Dagupan City rendered judgment for petitioners ordering reconveyance; the Court of Appeals affirmed with modification (deleting attorney’s fees) in a February 6, 2004 decision which became final and executory on March 8, 2004. After that judgment, respondents filed a separate complaint for reimbursement for useful expenses under Articles 448 and 546 of the New Civil Code, alleging they in good faith built a new house on the lot in 1995–1996 costing P800,000, believing themselves owners and not prevented by petitioners; they sought indemnity or the owner’s option under Article 448. Petitioners answered that respondents knew the deeds were fictitious and thus were builders in bad faith, precluding indemnity.
On January 5, 2011 respondents manifested the option to buy the land; petitioners declined to sell or to buy the house. The RTC, Branch 42, Dagupan City, on February 18, 2011, ordered the defendants to sell the land where plaintiffs’ house stood to plaintiffs at a reasonable price based on BIR zonal value. The CA, in a Decision dated September 17, 2013, affirmed the RTC with modifications and remanded the case for further proceedings consistent with Articles 448, 546 and 548...(Pro-only)
Issues:
- Did the Court of Appeals err in ruling that petitioners failed to prove respondents acted in bad faith when they constructed the house on the disputed land?
- Did the Court of Appeals err in ruling that res judicata does not bar the present action for reimbursement ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)