Case Digest (G.R. No. 154512)
Facts:
This case revolves around a legal dispute involving Diosdado Sta. Romana (the appellant) and Carlos Imperio (the appellee), culminating in a decision rendered by the Supreme Court of the Philippines on December 29, 1965. The controversy began on January 6, 1943, with the execution of a power of attorney by Silvio R. Viola (the Principal) in favor of his brother, Dr. Jose P. Viola (the Agent), granting him authority to manage and administer several parcels of land in San Miguel, Bulacan. The principal sought to convert these lands into a residential subdivision until all lots were sold.
On April 26, 1946, the Principal petitioned the Court of First Instance of Bulacan for a second owner's duplicate of a Transfer Certificate of Title (TCT), citing the loss of the original. The court subsequently ordered the issuance of the duplicate. Meanwhile, on June 18, 1946, the Agent executed a deed to sell six lots covered by TCT No. 19556 to Pablo Ignacio. The deed was recorded on Jul
Case Digest (G.R. No. 154512)
Facts:
- Execution of Power of Attorney:
- On January 6, 1943, Silvio R. Viola (Principal) executed a power of attorney in favor of his brother, Dr. Jose P. Viola (Agent), authorizing the latter to manage and administer seven parcels of registered land in San Miguel, Bulacan, for subdivision and sale.
- The land included Lot No. 622, covered by Transfer Certificates of Title (TCT) Nos. 19556 and 19559.
- Loss and Replacement of Title:
- On April 26, 1946, the Principal filed a motion with the Court of First Instance of Bulacan to issue a second owner’s duplicate of TCT No. 19556, claiming the original was lost.
- The motion was granted on June 29, 1946, and a second duplicate of TCT No. 19556 was issued.
- Sale by the Agent:
- On June 18, 1946, the Agent executed a deed (Exhibit A) in favor of Pablo Ignacio, agreeing to sell six lots covered by TCT No. 19556.
- The deed and power of attorney were annotated on TCT No. 19556 on July 2, 1946.
- Subsequent Sales by the Principal and Appellant:
- On October 18, 1946, the Principal sold a 30-hectare land, including Lot No. 622, to appellant Diosdado Sta. Romana (Exhibit B).
- On October 25, 1946, the appellant sold the same land to appellee Carlos Imperio (Exhibit C). TCT No. 19556 was canceled, and TCT No. 28946 was issued in the appellee’s name.
- Sale to Occupants:
- On December 14, 1946, the appellee sold portions of Lot No. 622 to several occupants who were already lessees of the land. Separate TCTs were issued to each occupant.
- Legal Proceedings:
- Pablo Ignacio filed a case in the Court of First Instance of Bulacan on April 22, 1947, seeking to annul the sales made by the Principal, appellant, and appellee, and to recover possession of the land.
- The Principal, appellant, and appellee filed various answers and cross-claims.
- The lower court ruled in favor of Ignacio, declaring him the rightful owner and ordering the appellee and occupants to surrender their titles. The court also ordered the appellee to refund the occupants and the Principal to pay damages to Ignacio.
- The Court of Appeals affirmed the decision but amended it to order the appellant to reimburse the appellee P8,463, representing the amount to be refunded to the occupants.
Issues:
- Whether the Court of Appeals had jurisdiction to hear the case, given the amount involved exceeded its original jurisdiction.
- Whether the Court of Appeals erred in amending its decision without giving the appellant an opportunity to respond to the appellee’s motion for reconsideration.
- Whether the appellee is entitled to reimbursement from the appellant, despite being in pari delicto (equal fault).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)