Case Digest (G.R. No. 185745)
Facts:
On June 26, 1998, the heirs of Isidro Bangi and Genoveva Diccion filed a complaint for annulment of documents, cancellation of transfer certificates of titles, restoration of original certificate of title, and recovery of ownership plus damages against spouses Dominador and Gloria Marcos. This case was lodged at the Regional Trial Court (RTC) of Urdaneta City, Pangasinan, and was docketed as Civil Case No. U-6603. The complaint arose from a disputed land transaction regarding a 2,138-square meter parcel of land situated in San Manuel, Pangasinan, which was originally covered by Original Certificate of Title (OCT) No. 22361. The respondents claimed that their parents, Isidro and Genoveva, purchased a one-third portion of this land from Eusebio Bangi on November 5, 1943, as evidenced by a Deed of Absolute Sale. However, the respondents later discovered that the title was transferred to Dominador and others through a Deed of Absolute Sale dated August 10, 1995, purportedly execute
...Case Digest (G.R. No. 185745)
Facts:
- Background of the Case
- The dispute involves the subject property covered by Original Certificate of Title (OCT) No. 22361, a 2,138-square meter parcel located in San Manuel, Pangasinan.
- The property’s title history involves several transactions and alleged irregularities, including claims of forgery.
- Parties Involved
- Petitioners: Spouses Dominador Marcos and Gloria Marcos.
- Respondents: Heirs of Isidro Bangi and Genoveva Diccion, represented by Nolito Sabiano, together with other impleaded parties such as the spouses of Jose Dilla and Pacita Dilla, Ceasaria Alap, and the spouses of Emilio Sumajit and Zenaida Sumajit.
- Timeline and Transactions
- On June 26, 1998, the respondents filed a complaint with the Regional Trial Court (RTC) of Urdaneta City, Pangasinan, seeking:
- Annulment of certain deeds;
- Cancellation of Transfer Certificates of Title (TCT Nos. T-47829 and T-48446); and
- Restoration of OCT No. 22361.
- The respondents alleged that:
- Their parents, Isidro and Genoveva, purchased a one-third portion of the subject property on November 5, 1943 through a Deed of Absolute Sale executed by Eusebio Bangi;
- Later, in 1995, a Deed of Absolute Sale dated August 10, 1995 transferred the title to Dominador, Primo Alap, Jose Dilla, and Emilio Sumajit, which was then allegedly sold in another transaction on November 21, 1995 resulting in the issuance of TCT Nos. T-47829 and T-48446.
- Key Allegations Raised by the Respondents:
- The Deed of Absolute Sale dated August 10, 1995 is a forgery, since it was allegedly executed by Alipio Bangi, who had been dead since 1918, and with the consent of Ramona Diccion who died in 1957.
- The Deed of Absolute Sale dated November 21, 1995 is also challenged as a forgery on the ground that Primo Alap, one of the purported signatories, had died in 1972.
- Petitioners' Defense and Counterclaims:
- They claim ownership over the subject property, including the one-third portion said to be sold by Eusebio.
- It is asserted that the subject property was originally owned by Alipio Bangi, and ownership had been transferred to Eusebio and his siblings through an oral partition after Alipio’s death in 1918.
- The Role of Extrajudicial Partition:
- An extrajudicial partition with quitclaim dated May 8, 1995 was executed by Espedita and Jose Bangi, purportedly confirming the prior oral partition which assigned the subject property to Eusebio.
- The authenticity and timing of this partition were questioned due to its execution long after Alipio Bangi’s demise.
- Proceedings and Decisions
- RTC Decision (March 26, 2007):
- Declared the Deeds of Absolute Sale dated August 10, 1995 and November 21, 1995, as well as the related TCTs, null and void on the ground that the deed of 1995 was forged.
- Upheld the validity of the Deed of Absolute Sale dated November 5, 1943 by Eusebio Bangi in favor of the spouses Isidro and Genoveva.
- Court of Appeals (CA) Decision (September 30, 2008):
- Affirmed the RTC’s decision.
- Ruled that despite questions regarding the donation propter nuptias from Alipio to Eusebio, Eusebio had already acquired title to the subject property through succession and an oral partition by his siblings.
- Further Developments:
- The petitioners sought a reconsideration of the CA’s decision, which was denied in a Resolution dated December 4, 2008.
- The case was elevated to the Supreme Court through a Petition for Review on Certiorari under Rule 45.
Issues:
- Whether the CA committed reversible error in affirming the RTC’s decision upholding the validity of the Deed of Absolute Sale dated November 5, 1943 executed by Eusebio Bangi in favor of the spouses Isidro and Genoveva.
- Whether Eusebio Bangi had valid title to the subject property at the time of the sale, having obtained it through an oral partition among the heirs of Alipio Bangi.
- Whether questions pertaining to the partition of Alipio Bangi’s estate, being essentially factual, should be subject to a review under Rule 45, which is limited to questions of law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)