Case Digest (G.R. No. 246096)
Facts:
Spouses Benny and Normita Rol v. Isabel Urdas Racho, G.R. No. 246096, January 13, 2021, Supreme Court Second Division, Perlas‑Bernabe, J., writing for the Court.
Respondent Isabel Urdas Racho filed a complaint for reivindicacion and damages alleging that her brother, Loreto Urdas, was the registered owner of Lot No. 1559 (Original Certificate of Title O‑1061), and that upon his death in 1963 his four siblings—Fausto Urdas, Sr., Chita Urdas, Maria Urdas Baclig and Isabel—became his intestate heirs. Isabel discovered that Lot No. 1559 had been subdivided into Lot Nos. 1559‑A and 1559‑B and that new titles (TCT Nos. T‑156992 and 032‑2012004566) were issued to petitioners on the basis of several instruments, including deeds dated September 1, 2006 and June 19, 2012 purporting to be executed by Loreto.
Petitioners answered and counterclaimed, claiming they acquired Lot No. 1559‑A in 1993 through an Extrajudicial Settlement with Sale (EJSS) executed by Fausto, Chita, Maria and Allan (Fausto’s son), which subdivided the lot and adjudicated Lot No. 1559‑A to Fausto, Chita and Maria who sold it to petitioners; Lot No. 1559‑B was adjudicated to Allan, who later sold it to petitioners by a deed dated September 26, 2011. Petitioners asserted open, continuous, and peaceful possession since 1993 (for 1559‑A) and since 2010 (for 1559‑B).
The Regional Trial Court (RTC), Branch 8, Aparri, Cagayan, in a Decision dated July 8, 2015, declared null and void the EJSS (September 13, 1993), the Deed of Sale dated September 26, 2011, and the two deeds purporting to be signed by Loreto (2006 and 2012). The RTC found the 2006 and 2012 deeds were forgeries (Loreto died in 1963) but held petitioners to be purchasers in good faith; it ordered reconveyance of 312.25 sq. m. to Isabel and awarded actual damages, attorney’s fees and costs. The RTC denied petitioners’ motion for reconsideration on September 3, 2015.
Petitioners appealed to the Court of Appeals (CA). The CA, in its Decision of September 13, 2018, affirmed with modification: it declared the EJSS void for excluding Isabel, held Allan’s adjudication void, but validated the sale of Lot No. 1559‑A to petitioners only insofar as Fausto, Chita and Maria’s respective undivided shares were concerned (totaling 468.375 sq. m.). The CA found petitioners to be in bad faith for failing to inquire about the sellers’ authority and deleted the RTC’s award of actual damages while a...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly rule that the EJSS and the instruments purporting to transfer Lot No. 1559 are null and void (except as to the portion representing the undivided shares sold by Fausto, Chita and Maria to petitioners)?
- Are petitioners innocent purchasers for value and is Isabel barred by laches from asse...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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