Case Digest (G.R. No. 187524) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Maria Butiong and Francisco Villafria, substituted by Dr. Ruel B. Villafria, petitioners, vs. Ma. Gracia Riaoza Plazo and Ma. Fe Riaoza Alaras, respondents (G.R. No. 187524, August 5, 2015), the dispute arose from the intestate death on November 16, 1989 of Pedro L. Riaoza, who left real properties in Nasugbu, Batangas, including a resort covered by Transfer Certificates of Title (TCT) Nos. 51354 and 51355 and a family home covered by TCT Nos. 40807 and 40808. His children by his first wife, respondents Ma. Gracia R. Plazo and Ma. Fe Alaras, alleged that Pedro’s second wife, Benita Tenorio Riaoza, together with her and Pedro’s younger children, had sold these properties in March 1991 to spouses Francisco Villafria and Maria Butiong without respondents’ knowledge or consent. Respondents claimed Benita showed them a document supposedly evidencing her share in the sale but which, on inquiry at Banco Silangan, proved to be a receipt for a prior loan payment. A title searc Case Digest (G.R. No. 187524) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and properties
- Pedro L. Riaza died intestate on November 16, 1989, leaving several heirs including Ma. Gracia Riaoza Plazo and Ma. Fe Riaoza Alaras (first‐wife children) and Benita Tenorio Riaza (second wife) with her issue.
- The decedent owned a resort (TCT Nos. 51354, 51355; 351 sq.m. each) and a family home (TCT Nos. 40807, 40808) in Nasugbu, Batangas.
- Alleged irregular sale
- In March 1991, the first‐wife heirs discovered that Benita and other second‐wife heirs purportedly sold the resort and family home to spouses Francisco Villafria and Maria Butiong (now substituted by their son, Dr. Ruel B. Villafria) without their knowledge or consent.
- Benita produced an alleged “receipt” of P87,352.62 from Banco Silangan, but it evidenced a bank loan payment, not the sale proceeds.
- Trial court proceedings
- Respondents filed an Amended Complaint for Judicial Partition with Annulment of Title and Recovery of Possession on September 15, 1993, praying (a) judicial partition of Pedro’s estate, (b) annulment of conveyance documents, (c) recovery of possession, and (d) issuance of new titles.
- Petitioners denied knowledge of the alleged sale, claimed good faith, and produced an Extra-Judicial Settlement and a Deed of Sale (defective, undated, unregistered, notarized by a non-commissioned notary).
- On October 1, 2001, the RTC nullified the Extra-Judicial Settlement and Deed of Sale for formal defects, ordered possession returned to respondents, improvements forfeited, and new titles issued to legitimate heirs.
- Appeals and collateral proceedings
- The Court of Appeals (CA) affirmed on October 31, 2006, ruling the defective notarization invalidated the deeds and petitioners failed to prove authenticity under Rule 132, Sec. 20 of Evidence.
- Petitioners’ Rule 45 petition was denied by the Supreme Court on June 20, 2007 for procedural deficiencies. Subsequent motions for reconsideration and requests to revisit on merits were denied.
- Petitioners filed a Petition for Annulment of Judgment before the CA (Feb. 11, 2009) on grounds of extrinsic fraud and lack of jurisdiction; dismissed on March 13, 2009, and the denial was upheld April 23, 2009.
- Petitioners filed the instant petition for review on certiorari under Rule 45 on June 10, 2009.
Issues:
- Jurisdiction
- Whether the RTC acted without jurisdiction by entertaining settlement of estate, judicial partition, annulment of title, and recovery of possession in one proceeding.
- Validity of conveyance and good-faith acquisition
- Whether petitioners proved the authenticity and validity of the Extra-Judicial Settlement and Deed of Sale.
- Whether petitioners qualify as purchasers in good faith and builders in good faith.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)