Case Digest (G.R. No. 83974)
Facts:
In Spouses Narciso Rongavilla and Dolores Rongavilla vs. Court of Appeals and Mercedes dela Cruz and Florencia dela Cruz, G.R. No. 83974, decided August 17, 1998, petitioners Dolores and her husband Narciso Rongavilla acquired by a Deed of Absolute Sale dated June 3, 1976, a 131-sqm residential parcel in Manuyo, Las Piñas, Rizal, originally co-owned by respondents Mercedes (60) and Florencia dela Cruz (71) and another niece. In May 1976, petitioners lent the elderly respondents ₱2,000 for roof repairs. Shortly thereafter, Dolores and her sister Juanita Jimenez presented a typewritten English document to respondents, representing in Tagalog that it merely acknowledged the loan. Unaware of its true nature, respondents executed the paper, which was later registered as TCT No. S-28903 in petitioners’ names and mortgaged for ₱40,000 with Cavite Development Bank. In February 1981, respondents filed before the Pasay RTC a complaint to declare the deed “void and inexistent” for fraud, lCase Digest (G.R. No. 83974)
Facts:
- Parties and Relationship
- Petitioners: Spouses Narciso Rongavilla and Dolores Rongavilla, niece and nephew-in-law of respondents.
- Private Respondents: Mercedes de la Cruz (60) and Florencia de la Cruz (71), aunts of Dolores, co-owners (½ share) of a 131 sqm land in Manuyo, Las Piñas (OCT No. 5415; later TCT No. S-28903).
- Loan and Purported Sale
- May 1976: Respondents borrow ₱2,000 from petitioners to repair their rooftop.
- June 3, 1976: Petitioners present a typewritten English document, represented as a loan acknowledgment, which respondents sign. The document is registered as a Deed of Absolute Sale showing ₱2,000 consideration.
- Discovery and Litigation History
- September 1980: Petitioners demand respondents vacate the land. Respondents discover their OCT cancelled, TCT No. S-28903 issued to petitioners, and the land mortgaged for ₱40,000.
- February 3, 1981: Respondents file complaint in RTC Pasay City, praying to declare the deed void, alleging lack of consent, want of consideration, fraud and misrepresentation; prayer for reconveyance, attorney’s fees and costs.
- RTC Decision: Declares the Deed of Absolute Sale void and inexistent; orders reconveyance, payment of ₱5,000 attorney’s fees and costs.
- Court of Appeals: Affirms the RTC decision in toto (March 11, 1988); denies reconsideration (June 28, 1988).
- Supreme Court: Petition for certiorari reinstated (Sept. 2, 1991); full briefing and oral arguments ensue.
Issues:
- Validity of the Deed of Absolute Sale
- Was the deed void and inexistent for lack of consent and consideration?
- Prescription
- Did the action to annul or declare the deed void prescribe after four years from execution and registration?
- Reliance on BIR Certificate
- Did the CA commit grave abuse by considering a Bureau of Internal Revenue certification not formally offered in evidence?
- Reconveyance Order
- Did the CA exceed jurisdiction or commit error in ordering petitioners to reconvey the property?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)